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Osborn v. Haley
https://api.oyez.org/cases/2006/05-593
05-593
2006
Pat Osborn
Barry Haley et al.
<p>Pat Osborn, an employee of a private contractor for the U.S. Forest Service, sued Barry Haley, an employee of the Forest Service, in state court. Osborn alleged that Haley had influenced her employer to fire her. Under the Westfall Act, federal employees are immune from such lawsuits if the employee acts "within the scope of his employment." If the Attorney General certifies that the employee acted within his scope, the case can be transferred to federal court and the United States can be substituted for the employee as the defendant. The government conceded that if Osborn's version of events were correct, Haley would have been outside his scope. Nevertheless, the government certified that Haley was within his scope, because it denied that Haley had any role in Osborn's firing.</p> <p>The government brought the case to federal District Court, but the court decided that it lacked the authority to settle the factual dispute at the root of the Attorney General's certification. Instead, the court assumed that Osborn's account was true, ruled that Haley had been outside the scope of his employment by influencing Haley's firing, and sent the case back to state court.</p> <p>The government appealed to the Court of Appeals for the Sixth Circuit, which reversed the lower court. The Circuit Court ruled that the Westfall Act gives the courts power to settle factual disputes over the incident at issue in a lawsuit, even if the dispute is over whether or not the incident happened at all. The Sixth Circuit also ruled that the District Court should not have sent the case back to state court, because the Westfall Act gives the federal courts jurisdiction over the case even after the federal District Court finds that the Attorney General was wrong to certify the federal employee.</p> <p>Osborn appealed to the Supreme Court, which instructed the parties to submit briefs on the additional question of whether the Westfall Act gives a Court of Appeals the authority to review a District Court's order remanding a case back to state court.</p>
2,059
7
2
false
majority opinion
affirmed
Judicial Power
1,801
55,420
Altadis USA, Inc. v. Sea Star Line, LLC
https://api.oyez.org/cases/2006/06-606
06-606
2006
Altadis USA, Inc.
Sea Star Line, LLC, et al.
<p>Altadis USA, Inc. hired Sea Star Line, LLC (Sea Star) to ship a container of cigars from San Juan, Puerto Rico, to Tampa, Florida. According to the contract, which was negotiated under the Carriage of Goods by Sea Act (COGSA), the container would travel by ship until it reached port at Jacksonville, Florida. From there, American Trans-Freight, Inc. (ATF) would truck it to Tampa. Sea Star issued a "'through' bill of lading" which held Sea Star liable for the container's safety during both the land and sea portions of its transport. The container was stolen from an ATF truck and Altadis filed a claim against Sea Star in District Court. The one-year statute of limitations for filing a COGSA claim had expired and the District Court dismissed the suit. Altadis argued that the Carmack Amendment imposed a two-year minimum statute of limitations period on liability claims relating to the transport of goods into the United States.</p> <p>The U.S. Court of Appeals for the Eleventh Circuit ruled that the Carmack Amendment's liability rules did not apply to the inland portion of transport because ATF did not issue a separate bill of lading. Other U.S. Courts of Appeals had ruled that the Carmack Amendment did not require a separate bill of lading to cover the inland portion of transport.</p>
1,304
0
0
false
dismissal - rule 46
none
null
1,802
55,422
Wilkie v. Robbins
https://api.oyez.org/cases/2006/06-219
06-219
2006
Charles Wilkie et al.
Harvey Frank Robbins
<p>Harvey Robbins owned a private dude ranch which was intermingled with federal lands. The previous owner had granted the Bureau of Land Management (BLM) right-of-way across the private land, but after Robbins bought the ranch he refused to re-grant it. Robbins alleged that BLM officials harassed him with threats and meritless criminal charges, with the aim of forcing him to grant the government right-of-way. Robbins sued the BLM officials for extortion in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). He also brought a <em>Bivens</em> action (an action seeking monetary damages from a federal agent for a constitutional violation). Robbins argued that the Fifth Amendment protects a "right to exclude" government officials from one's property, and that the BLM agents had retaliated against him for his exercise of this right. The District Court dismissed both claims, but the U.S. Court of Appeals for the Tenth Circuit reversed. On appeal to the Supreme Court, the government argued that the BLM officials, while acting on behalf of the government, had qualified immunity and therefore could not be sued for extortion under RICO. The government also claimed that no <em>Bivens</em> action could be brought, because review of the BLM's actions was already available under the Administrative Procedure Act.</p>
1,348
7
2
true
majority opinion
reversed/remanded
Economic Activity
1,803
55,424
Limtiaco v. Camacho
https://api.oyez.org/cases/2006/06-116
06-116
2006
Alicia G. Limtiaco, Attorney General of Guam
Felix P. Camacho, Governor of Guam
<p>Governor Camacho of Guam sought to borrow over $400 million through the issuance of bonds. Guam Attorney General Moylan argued that the bond issuance violated the Guam Organic Act, a federal law governing the Territory of Guam. The Organic Act sets the limit for government borrowing to 10% of the "aggregate tax valuation of the property on Guam." The Governor asked the Supreme Court of Guam for a decision on the disputed text. The Guam legislature had interpreted the phrase "aggregate tax valuation" to mean the assessed value of property on Guam for purposes of taxation. However, the Guam Supreme Court declined to follow the legislature's interpretation and ruled that the "aggregate tax valuation" was equivalent to the full appraised value of property on Guam. Under that interpretation, the debt-limit would be about $1.1 billion.</p> <p>The Attorney General appealed to the U.S. Court of Appeals for the Ninth Circuit. While the case was pending, Congress passed a law allowing parties to appeal directly from the Guam Supreme Court to the U.S. Supreme Court. When the Ninth Circuit declined to hear the case, Moylan appealed to the Supreme Court. Normally parties must seek Supreme Court review within 90 days of a lower court's decision, but the case had been pending before the Ninth Circuit for two years. The Supreme Court directed the parties to argue the question of whether the time the case was pending before the Ninth Circuit counted toward the time limit.</p>
1,487
5
4
true
majority opinion
reversed/remanded
Economic Activity
1,804
55,423
Travelers Casualty & Surety Co. of America v. Pacific Gas & Electric Co.
https://api.oyez.org/cases/2006/05-1429
05-1429
2006
Travelers Casualty & Surety Company of America
Pacific Gas & Electric Company
<p>Prior to declaring bankruptcy, Pacific Gas &amp; Electric company (PG &amp; E) purchased surety bonds from Travelers Casualty and Surety Company of America (Travelers). These bonds obliged Travelers to settle debts PG &amp; E couldn't repay. When PG &amp; E went bankrupt, Travelers hired attorneys to protect its interests. State law mandated that PG &amp; E cover all attorney fees incurred by Travelers during state bankruptcy proceedings. The litigation later moved to federal court. PG &amp; E refused to pay for Travelers's expenditures in federal court, claiming responsibility only for fees incurred during state proceedings.</p> <p>The Bankruptcy Court denied Travelers's request for reimbursement because the precedents of the U.S. Court of Appeals for the Ninth Circuit held that only federal laws could ensure payment for federal litigation. PG &amp; E was only under contractual and legal obligation to pay for state-court attorney fees. The District Court and the Ninth Circuit denied Travelers's claim on the same grounds. Travelers appealed to the Supreme Court, citing inconsistent rulings among the Circuit Courts of Appeals.</p>
1,151
9
0
true
majority opinion
vacated/remanded
Attorneys
1,805
55,425
Gonzales v. Carhart
https://api.oyez.org/cases/2006/05-380
05-380
2006
Alberto R. Gonzales, Attorney General
Leroy Carhart et al.
<p>In 2003, Congress passed and the President signed the Partial-Birth Abortion Ban Act. The controversial concept of partial-birth abortion is defined in the Act as any abortion in which the death of the fetus occurs when "the entire fetal head [...] or [...] any part of the fetal trunk past the navel is outside the body of the mother." Dr. Leroy Carhart and other physicians who perform late-term abortions sued to stop the Act from going into effect. The plaintiffs argued that the Act could apply to a more common abortion procedure known as "D&amp;E" ("dilation and evacuation"), as well as to the less common "intact D&amp;E," sometimes called D&amp;X ("dilation and extraction"). With this application the Act would ban most late-term abortions and thus be an unconstitutional "undue burden" on the right to an abortion, as defined by the Supreme Court in <em>Planned Parenthood v. Casey</em>. The plaintiffs also argued that the Act's lack of an exception for abortions necessary to protect the health of the mother rendered it unconstitutional under the Supreme Court's decision in <em>Stenberg v. Carhart</em>, regardless of Congress's finding in the Act that partial-birth abortions are never medically necessary.</p> <p>A federal District Court agreed and ruled the Act unconstitutional on both grounds. The government appealed to the Court of Appeals for the Eighth Circuit. The government argued that the Act only bans a narrow category of abortion procedures, and that a health exception is not required when Congress determines that a banned abortion procedure is never necessary for the health of the mother. The Eighth Circuit disagreed and upheld the District Court, ruling that a health exception is required for all bans on abortion procedures when "substantial medical authority" supports the necessity of the procedure. The Circuit Court ruled that the ongoing disagreement among medical experts over the necessity of intact D&amp;E abortions was sufficient to establish that the Act was unconstitutional without a health exception. The Circuit Court did not reach the question of whether the Act was so broad as to qualify as an unconstitutional "undue burden."</p>
2,192
5
4
true
majority opinion
reversed
Privacy
1,806
55,426
Safeco Insurance Co. of America v. Burr
https://api.oyez.org/cases/2006/06-84
06-84
2006
Safeco Insurance Company of America et al.
Charles Burr et al.
<p>In No. 06-100, Edo, a consumer, sued GEICO General Insurance Company, alleging that GEICO had violated the requirement in the Fair Credit Reporting Act (FCRA) that insurance companies give consumers notice before raising rates. Edo sought statutory and punitive damages, which the FCRA awards only when a company "willfully" violates the law. Similarly, in 06-84, several consumers sued Safeco for failing to notify them that better credit ratings would have entitled them to better premiums. It was GEICO's policy to notify new applicants only if their credit ratings were worse than a certain "neutral" (average) value, while Safeco as a matter of policy did not give "adverse action" notices to any new applicants. GEICO argued that it was unaware that the FCRA applied to the setting of premiums for new applicants such as Edo, and thus could not be considered to have acted willfully. The District Court ruled for GEICO and Safeco, holding that their actions did not qualify as willful.</p> <p>On appeal, the Court of Appeals for the Ninth Circuit reversed, holding that that the concept of willfulness includes "reckless disregard" for the law as well as actual knowledge that the conduct was illegal. The ruling put the Ninth Circuit in conflict with most other circuit courts, but the court argued that its interpretation was more consistent with Supreme Court precedent and the purpose of the FCRA.</p>
1,415
9
0
true
majority opinion
reversed/remanded
Economic Activity
1,807
55,427
Zuni Public School Dist. No. 89 v. Department of Education
https://api.oyez.org/cases/2006/05-1508
05-1508
2006
Zuni Public School District No. 89 et al.
United States Department of Education et al.
<p>The Department of Education certified that the state of New Mexico equalizes educational expenditures among school districts. The certification of equalization allowed New Mexico to offset its funding of districts located on Indian Reservations by a proportion of the federal Impact Aid payments made to those districts. Zuni Public School District objected to the certification, arguing that the Department had not followed the statutory formula for determining that a state's expenditures are equalized. Outlier school districts falling above the 95th or below the 5th percentile in per-pupil expenditures were excluded from consideration when the Department determined equalization. The Department calculated these percentiles based on the total student population, but Zuni argued that 20 U.S.C. Section 7709 had repealed that policy.</p> <p>An administrative judge dismissed Zuni's complaint, and the Secretary of Education affirmed on the ground that the law was ambiguous. A divided panel of the U.S. Circuit Court of Appeals for the Tenth Circuit upheld the Secretary's decision as a valid interpretation of the statute. In a rehearing by the entire Circuit Court, the 12 judges split evenly, again upholding the ruling.</p>
1,236
5
4
false
majority opinion
affirmed
Judicial Power
1,808
55,428
EC Term of Years Trust v. United States
https://api.oyez.org/cases/2006/05-1541
05-1541
2006
EC Term of Years Trust
United States
<p>The Internal Revenue Service (IRS) contended that Elmer and Dorothy Cullers had established a trust for the purpose of evading taxes. The IRS filed tax liens against the trust, freezing the trustees' assets until the outstanding taxes were paid. The trustees disagreed with the IRS, but opened a bank account to settle the tax dispute. A month later, the IRS collected the outstanding taxes from the bank account. EC Term of Years Trust sued the IRS pursuant to 26 U.S.C. 7426, which entitles trustees to challenge wrongful IRS collections, and 28 U.S.C. 1346(a)(1), which entitles taxpayers to recover erroneously collected taxes. A district court decided that only 26 U.S.C. 7426 allowed third-party tax recoveries, so the court lacked jurisdiction under 28 U.S.C. 1346(a)(1), the general provision for tax recovery. The court dismissed the 26 U.S.C. 7426 claim because the nine-month filing time limit had expired. EC Trust claimed in a second suit that the Supreme Court's opinion in <em>United States v. Williams</em> meant that the possibility of a suit under 26 U.S.C. 7426 did not preclude suits under 28 U.S.C. 1346(a)(1). The District Court rejected the argument, and the U.S. Court of Appeals for the Fifth Circuit affirmed.</p>
1,243
9
0
false
majority opinion
affirmed
Federal Taxation
1,809
55,429
Ledbetter v. Goodyear Tire and Rubber Company
https://api.oyez.org/cases/2006/05-1074
05-1074
2006
Lilly M. Ledbetter
The Goodyear Tire & Rubber Company, Inc.
<p>Over her nineteen-year career at Goodyear Tire, Lilly Ledbetter was consistently given low rankings in annual performance-and-salary reviews and low raises relative to other employees. Ledbetter sued Goodyear for gender discrimination in violation of Title VII of the Civil Rights Act of 1964, alleging that the company had given her a low salary because of her gender. A jury found for Ledbetter and awarded her over $3.5 million, which the district judge later reduced to $360,000.</p> <p>Goodyear appealed, citing a Title VII provision that requires discrimination complaints to made within 180 days of the employer's discriminatory conduct. The jury had examined Ledbetter's entire career for evidence of discrimination, but Goodyear argued that the jury should only have considered the one annual salary review that had occurred within the 180-day limitations period before Ledbetter's complaint.</p> <p>The U.S. Court of Appeals for the Eleventh Circuit reversed the lower court, but without adopting Goodyear's position entirely. Instead the Circuit Court ruled that the jury could only examine Ledbetter's career for evidence of discrimination as far back as the last annual salary review before the start of the 180-day limitations period. The Circuit Court ruled that the fact that Ledbetter was getting a low salary during the 180 days did not justify the evaluation of Goodyear's decisions over Ledbetter's entire career. Instead, only those annual reviews that could have affected Ledbetter's payment during the 180 days could be evaluated. The Circuit Court found no evidence of discrimination in those reviews, so it reversed the District Court and dismissed Ledbetter's complaint.</p>
1,704
5
4
false
majority opinion
affirmed
Civil Rights
1,810
55,430
Jones v. Bock
https://api.oyez.org/cases/2006/05-7058
05-7058
2006
Lorenzo L. Jones
Barbara Bock, Warden, et al.
<p>Congress passed the Prisoner Litigation Reform Act (PLRA) in 1995 in an effort to cut down on frivolous lawsuits by prisoners. Under the PLRA, before bringing a federal civil rights suit a prisoner must go through his prison's internal complaint process. Only after exhausting all of these "administrative remedies" can the prisoner bring the complaint to federal court.</p> <p>Lorenzo Jones sustained serious injuries in a car accident while in custody. He sued prison officials in federal court, claiming that they were violating his Eighth Amendment rights by making him do arduous work despite his injuries. The officials moved to dismiss the suit, because Jones had not provided any evidence or description of the administrative remedies he claimed to have pursued. The District Court granted the motion and dismissed the suit.</p> <p>On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed. The Circuit Court ruled that in order for Jones to sue, he would have had to provide the court with copies of his grievance forms or at least describe the administrative processes he had exhausted. The Circuit Court further ruled that the PLRA requires "total exhaustion," which means that if a prisoner's suit has multiple claims, administrative remedies must have been exhausted for each and every claim.</p> <p>The Supreme Court accepted review in order to resolve the conflict between Circuit Courts over which side bears the burden of proving exhaustion of administrative remedies.</p> <p>In <em>Williams v. Overton</em>, Timothy Williams suffered from a medical condition which caused tumor growth and disfigurement in his arm. He claimed that prison officials were violating his rights by ignoring his medical needs. Williams's complaint had two claims: he needed additional surgery on his arm and a single-occupancy, handicapped-accessible cell. Williams went through the administrative remedial process on both grievances and both claims were denied. Williams then sued in federal court.</p> <p>The District Court dismissed the suit, because Williams had neglected to name any prison officials as defendants in his medical complaint. Therefore, the court ruled, the administrative remedies for that claim could not be considered to have been exhausted.</p> <p>On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed, ruling that "The prisoner must demonstrate that he has exhausted the administrative remedies with respect to each individual he intends to sue." The Circuit Court also ruled that the PLRA requires "total exhaustion," which meant that Williams's entire suit was dismissed because of his unexhausted medical claim, even though the administrative remedies for his request for a new cell had been exhausted.</p>
2,758
9
0
true
majority opinion
reversed/remanded
Criminal Procedure
1,811
55,432
Smith v. Texas
https://api.oyez.org/cases/2006/05-11304
05-11304
2006
LaRoyce Lathair Smith
Texas
<p>LaRoyce Smith was convicted of murder and sentenced to death. In 2004, the Supreme Court overturned his death sentence and sent the case back to state court because of a judge's improper jury instruction. (See <em> <a href="/cases/2004/04_5323/">Smith v. Texas</a> </em>, No. 04-5323.) Nevertheless, the Texas Court of Criminal Appeals re-imposed the sentence, holding that the erroneous instruction had not done any "egregious harm" to the fairness of Smith's sentencing. The Texas court found that the jury had still been able to consider all relevant mitigating evidence, despite the unconstitutional instruction. The Supreme Court agreed to review the case a second time.</p>
683
5
4
true
majority opinion
reversed/remanded
Criminal Procedure
1,812
55,433
Hinck v. United States
https://api.oyez.org/cases/2006/06-376
06-376
2006
John F. Hinck et ux.
United States
<p>The Internal Revenue Service (IRS) assessed over $20,000 in interest fees for outstanding taxes against John and Pamela Hinck. The Hincks claimed that the interest accrued because of IRS delays and errors. Section 6404(e)(1) of the Internal Revenue Code authorizes the abatement of interest fees that are caused by IRS delays. The IRS rejected the Hincks' interest abatement claim in 2000. In 2003, the United States Court of Federal Claims determined that it had no jurisdiction to hear the case because Section 6404(h) of the Internal Revenue Code granted the United States Tax Court jurisdiction over interest abatement disputes.</p> <p>The Hincks appealed to the United States Court of Appeals for the Federal Circuit, arguing that the Tucker Act granted subject matter jurisdiction to the Federal Claims Court. The Federal Circuit held that Section 6404(h) grants the Tax Court exclusive jurisdiction over interest abatement disputes. The U.S. Court of Appeals for the Fifth Circuit had previously ruled to the contrary.</p>
1,033
9
0
false
majority opinion
affirmed
Federal Taxation
1,813
55,439
Global Crossing Telecommunications, Inc. v. Metrophones Telecommunications, Inc.
https://api.oyez.org/cases/2006/05-705
05-705
2006
Global Crossing Telecommunications, Inc.
Metrophones Telecommunications, Inc.
<p>In the Telecommunications Act of 1996, Congress declared that payphone service providers (PSPs) must be compensated for every completed call using their payphones. Previously, PSPs were not compensated for coinless "dial-around" long-distance calls in which the caller pays a long distance carrier rather than the PSP. The Federal Communications Commission (FCC) adopted rules requiring the carriers to pay the PSPs on a per-call basis. Metrophones Telecommunications, a PSP, sued Global Crossing Telecommunications, a long-distance carrier, alleging that Global Crossing had failed to pay for calls placed from Metrophones's payphones.</p> <p>The District Court dismissed Metrophones's first complaint because the Telecommunications Act of 1996 did not create a private right of action to recover compensation from long-distance carriers. Metrophones then filed an amended complaint based on Section 201(b) of the Communications Act of 1934, which deals with "unjust and unreasonable" practices of carriers. Global Communications argued that Metrophones had no right to sue under this statute either, but the District Court disagreed and ruled for Metrophones.</p> <p>The Ninth Circuit Court of Appeals affirmed this decision. The Circuit Court relied heavily on the FCC's interpretation of the statute, which was that failure to pay compensation to PSPs is an "unjust and unreasonable" practice in violation of Section 201(b) and that PSPs have a private right of action to sue carriers for such violations. The Circuit Court held that though the FCC rule on the subject was brief, it was entitled to deference from the courts in the absence of specific guidance from the statute.</p>
1,690
7
2
false
majority opinion
affirmed
Economic Activity
1,814
55,435
Tellabs, Inc. v. Makor Issues & Rights, Ltd.
https://api.oyez.org/cases/2006/06-484
06-484
2006
Tellabs, Inc., et al.
Makor Issues & Rights, Ltd., et al.
<p>Several plaintiffs brought a class action securities fraud lawsuit against Tellabs, Inc., a manufacturer of equipment for fiber optic cable networks. The plaintiffs alleged that Tellabs had misrepresented the strength of its products and earnings in order to conceal the declining value of the company's stock. Under the Private Securities Litigation Reform Act of 1995 (PSLRA), plaintiffs bringing securities fraud complaints must allege specific facts that give rise to a "strong inference" that the defendant intended to deceive investors (scienter).</p> <p>The District Court dismissed the complaints. The court held that the plaintiff's allegations were too vague to establish a "strong inference" of scienter on the part of Tellabs. On appeal, the U.S. Court of Appeals for the Seventh Circuit reversed one of the lower court's dismissals. The Seventh Circuit ruled that a plaintiff need only allege "acts from which, if true, a reasonable person could infer that the defendant acted with the required intent." The Court of Appeals decided to consider only the plausibility of the inference of a guilty mental state, and not any competing inferences of an innocent mental state. This decision was due in part to the court's concern that weighing competing inferences was more properly the task of a jury. The Seventh Circuit's ruling conflicted with those of other Courts of Appeals, which required plaintiffs to show that the inference of scienter supported by the alleged facts was more plausible than any competing inference of innocent intent.</p>
1,561
8
1
true
majority opinion
vacated/remanded
Economic Activity
1,815
55,436
Office of Sen. Mark Dayton v. Hanson
https://api.oyez.org/cases/2006/06-618
06-618
2006
Office of Senator Mark Dayton
Brad Hanson
<p>Brad Hanson worked as State Office Manager for U.S. Senator Mark Dayton. Shortly after Hanson took medical leave for a heart problem, Dayton fired him. Hanson sued under the Congressional Accountability Act of 1995, claiming that Dayton had discriminated against him based on a perceived disability. Dayton filed a motion to have the case dismissed for lack of jurisdiction. He argued that he was immunized from the suit by the Speech or Debate Clause of the Constitution ("for any Speech or Debate in either House, [Senators and Representatives] shall not be questioned in any other Place.") Dayton claimed that because Hanson's duties were directly related to Dayton's legislative functions, the decision to fire him could not be challenged. The District Court denied the motion.</p> <p>Overturning its own precedent, the U.S. Court of Appeals for the District of Columbia Circuit affirmed the lower court's decision that the Speech or Debate Clause does not bar the suit. The clause can be invoked to exclude evidence that would involve legislative acts, but the D.C. Circuit ruled that it is not a blanket ban on suits involving legislative employees. The employee would simply have to make his case without questioning legislative acts or motivations for legislative acts. Senator Dayton appealed directly to the Supreme Court, arguing that the Accountability Act requires the Court to hear the appeal. He also argued that Hanson's suit should be dismissed because the case had become moot after Dayton retired from the Senate.</p>
1,540
8
0
false
majority opinion
null
Judicial Power
1,816
55,434
Norfolk Southern Railway Co. v. Sorrell
https://api.oyez.org/cases/2006/05-746
05-746
2006
Norfolk Southern Railway Company
Timothy Sorrell
<p>Sorrell, an employee of Norfolk Southern Railway, crashed his company truck while swerving to avoid another company truck. Sorrell suffered injuries and sued Norfolk Southern for damages under the Federal Employers Liability Act (FELA). Both Sorrell and the railroad had been negligent in the incident to some extent. Norfolk Southern argued that under the FELA, the "causation standard" - the standard for assigning the blame for an incident - was the same for both the employee and the railroad. According to Norfolk Southern, any damages awarded to Sorrell for the railroad's negligence had to be reduced by the amount of the damages that was attributable to Sorrell's own negligence. (If Sorrell was 60% responsible for the accident, for example, the damages would be reduced by 60%.)</p> <p>The trial ruled instead that the causation standards were different: the railroad was responsible for any negligence that contributed to the accident, but the employee was only responsible for negligence that directly caused damage. Under this more lenient standard for employee negligence, the trial court awarded Sorrell $1.5 million.</p> <p>The Missouri Court of Appeals affirmed. The Missouri Supreme Court declined to hear the case, but the U.S. Supreme Court granted review.</p>
1,284
9
0
true
majority opinion
vacated/remanded
Economic Activity
1,817
55,438
Gonzales v. Planned Parenthood Federation of America, Inc.
https://api.oyez.org/cases/2006/05-1382
05-1382
2006
Alberto R. Gonzales, Attorney General
Planned Parenthood Federation of America, Inc., et al.
<p>In 2003, Congress passed and the President signed the Partial-Birth Abortion Ban Act. The controversial concept of partial-birth abortion is defined in the Act as any abortion in which the death of the fetus occurs when "the entire fetal head [...] or [...] any part of the fetal trunk past the navel is outside the body of the mother."</p> <p>Planned Parenthood sued the Attorney General of the United States, arguing that the Act was unconstitutional under the right to an abortion protected by the substantive component of the Due Process Clause of the Fifth Amendment, as interpreted by the Supreme Court in <em>Roe v. Wade</em> and subsequent cases. The District Court agreed and stopped the Act from going into effect.</p> <p>On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed. Though the government claimed that the Act banned only a narrow, rare category of abortions, the Circuit Court ruled that the Act applied to the common abortion procedure known as "D&amp;E" ("dilation and evacuation"), as well as to the far less common "intact D&amp;E," sometimes called "D&amp;X" ("dilation and extraction"). This made the ban expansive enough to qualify as an unconstitutional "undue burden" on the right to abortion, as defined in <em>Planned Parenthood v. Casey</em>.</p> <p>The Ninth Circuit also ruled that the Act's lack of an exception for abortions necessary to protect the health of the mother rendered it unconstitutional. Congress had included in the Act a finding that partial-birth abortions were never medically necessary, but the Ninth Circuit held that the Supreme Court's decision in <em>Stenberg v. Carhart</em> required the health exception in all cases where medical opinion on the necessity an abortion procedure is divided.</p> <p>Finally, the Circuit Court ruled that the Act was unconstitutionally vague, because the inclusion of ambiguous statutory terms such as "partial-birth abortion" would prevent physicians from knowing which methods of abortion were covered. The Circuit Court determined that the proper course of action was to block enforcement of the entire Act.</p>
2,123
5
4
true
majority opinion
reversed
Privacy
1,818
55,437
Morse v. Frederick
https://api.oyez.org/cases/2006/06-278
06-278
2006
Deborah Morse et al.
Joseph Frederick
<p>At a school-supervised event, Joseph Frederick held up a banner with the message "Bong Hits 4 Jesus," a slang reference to marijuana smoking. Principal Deborah Morse took away the banner and suspended Frederick for ten days. She justified her actions by citing the school's policy against the display of material that promotes the use of illegal drugs. Frederick sued under 42 U.S.C. 1983, the federal civil rights statute, alleging a violation of his First Amendment right to freedom of speech. The District Court found no constitutional violation and ruled in favor of Morse. The court held that even if there were a violation, the principal had qualified immunity from lawsuit. The U.S. Court of Appeals for the Ninth Circuit reversed. The Ninth Circuit cited <em> <a href="/cases/1968/21/">Tinker v. Des Moines Independent Community School District</a> </em>, which extended First Amendment protection to student speech except where the speech would cause a disturbance. Because Frederick was punished for his message rather than for any disturbance, the Circuit Court ruled, the punishment was unconstitutional. Furthermore, the principal had no qualified immunity, because any reasonable principal would have known that Morse's actions were unlawful.</p>
1,264
5
4
true
majority opinion
reversed/remanded
First Amendment
1,819
55,440
Beck v. PACE International Union
https://api.oyez.org/cases/2006/05-1448
05-1448
2006
Jeffrey H. Beck, liquidating trustee of the Estates of Crown Vantage, Inc. and Crown Paper Company
PACE International Union et al.
<p>During Chapter 11 liquidation proceedings, Crown Vantage, Inc. (Crown) terminated its employee pension plan and purchased an annuity for the employee participants as a replacement. The participants advocated merging the current plan into a multiemployer PACE International Union (PACE) pension plan but Crown did not investigate the possibility. The participants alleged that Crown breached its fiduciary duties under the Employee Retirement Income Security Act of 1974 (ERISA) by not acting "solely in the interests of the participants" (Section 1104(a)(1)). A bankruptcy court ordered Crown to maintain the plan's funds until they were distributed to the participants.</p> <p>A District Court affirmed, finding that Crown failed to consider its employees' interest. Crown appealed to the U.S. Court of Appeals for the Ninth Circuit, claiming that it did not consider the PACE plan because Section 4041 of ERISA prevents termination by way of a merger into a multiemployer plan. The Ninth Circuit affirmed the District Court, ruling that ERISA does allow termination by way of a merger into a multiemployer plan.</p>
1,121
9
0
true
majority opinion
reversed/remanded
Economic Activity
1,820
55,441
Uttecht v. Brown
https://api.oyez.org/cases/2006/06-413
06-413
2006
Jeffrey Uttecht, Superintendent, Washington State Penitentiary
Cal Coburn Brown
<p>A Washington State jury sentenced Cal Brown to death for murder. Brown protested that unfair jury selection had guaranteed a "verdict of death." One potential juror who expressed willingness to impose the death penalty only in "severe situations" was dismissed by the judge for cause. The Washington Supreme Court upheld the dismissal.</p> <p>Brown appealed first to a federal district court and then to the U.S. Court of Appeals for the Ninth Circuit, which ruled that the dismissed juror was not "substantially impaired" in his ability to follow the law. Supreme Court precedent required that jurors only be dismissed if their personal views prevent them from performing their duties. The prosecution unsuccessfully petitioned for the Ninth Circuit to rehear the case en banc on the ground that the Anti-Terrorism and Effective Death Penalty Act required appeals courts to give deference to trial judges' evaluations of jurors.</p>
937
5
4
true
majority opinion
reversed/remanded
Criminal Procedure
1,821
55,442
Lance v. Coffman
https://api.oyez.org/cases/2006/06-641
06-641
2006
Keith Lance et al.
Mike Coffman, Colorado Secretary of State
<p>After the 2000 census, the U.S. Congress increased Colorado’s representation in the U.S. House of Representatives from six congressmen to seven. The Colorado state legislature failed to redraw the districts before the 2002 elections, so the state courts redrew the districts. In 2003, the Colorado state legislature redrew a different district map, which resulted in Colorado having two conflicting district maps. The Colorado Supreme Court ruled that the Colorado state constitution only allows district maps to be redrawn once per census, and therefore the courts’ 2002 redistricting took precedence over the redistricting by the state legislature.</p> <p>Keith Lance and three other Colorado citizens sued in federal district court and argued that the Colorado Supreme Court’s decision violated the Election Clause of Article I of the U.S. Constitution, and those individuals’ First and Fourteenth Amendment rights to file for redress of grievances. The district court held that they did not have jurisdiction and dismissed the case. Lance appealed to the U.S. Supreme Court, which held that the district court did have jurisdiction to hear the case. The Supreme Court remanded the case back to the district court of Colorado, which dismissed the case on the grounds of issue preclusion, since Lance was an individual citizen not directly affected by the redistricting ruling. Lance again appealed to the U.S. Supreme Court.</p>
1,435
9
0
false
per curiam
vacated/remanded
Judicial Power
1,822
55,444
Credit Suisse Securities (USA) LLC v. Billing
https://api.oyez.org/cases/2006/05-1157
05-1157
2006
Credit Suisse Securities (USA) LLC, fka Credit Suisse First Boston LLC, et al.
Glen Billing et al.
<p>Billing and other investors filed a class action lawsuit against Credit Suisse and other Wall Street investment firms. The lawsuit alleged that the firms had violated the Sherman Antitrust Act by conspiring to drive up the cost of initial public offering (IPO) securities during the stock market boom of the 1990s. The firms allegedly entered into illegal contracts with IPO purchasers, requiring subsequent investors to pay artificially inflated prices for the secutities. Credit Suisse argued that the suit should be dismissed, because the firms had implied antitrust immunity. It claimed that the firms' conduct was normal business practice, and was closely regulated by the Securities and Exchange Commission. If plaintiffs were able to bring antitrust suits against investment firms for securities violations, Credit Suisse argued, the plaintiffs would be able to subvert the securities laws that Congress intended to govern such suits.</p> <p>The federal District Court agreed with Credit Suisse and dismissed the lawsuit. On appeal, however, the U.S. Court of Appeals for the Second Circuit reversed the lower court and reinstated the suit. The Second Circuit held that there was no evidence that Congress had intended securities laws like the Securities Act of 1933 to foreclose antitrust suits challenging practices like those engaged in by Credit Suisse.</p>
1,372
7
1
true
majority opinion
reversed
Economic Activity
1,823
55,443
Philip Morris USA v. Williams
https://api.oyez.org/cases/2006/05-1256
05-1256
2006
Philip Morris USA
Mayola Williams, Personal Representative of the Estate of Jesse D. Williams, Deceased
<p>Jesse Williams died of lung cancer at age 67 after a life spent smoking three packs of Marlboro cigarettes per day. His widow sued Phillip Morris, the maker of Marlboro cigarettes, alleging that the company had engaged in a deliberate, wide-spread campaign of misinformation on the dangers of smoking. The jury found for Williams and awarded her $821,485.50 in compensatory damages and $79.5 million in punitive damages. However, the trial judge found the punitive damages excessive and reduced them to $32 million.</p> <p>Under the Supreme Court's decision <em>BMW v. Gore</em>, punitive damages must be reasonably related to the harm done to the plaintiff, but larger punitive damage awards may be appropriate if the defendant displayed reprehensible conduct. Citing <em>Gore</em>, the Oregon Court of Appeals reinstated the $79.5 million award, holding that Phillip Morris's conduct was reprehensible enough to warrant the large amount.</p> <p>The Oregon Supreme Court declined to take the case. However, the U.S. Supreme Court sent the case back for consideration in light of <em>State Farm v. Campbell</em>, which held that punitive damages can normally only be as much as nine times greater than compensatory damages. The Oregon Court of Appeals again affirmed the $79.5 million award, ruling that the reprehensibility of Phillip Morris's conduct justified the larger ratio. The Oregon Supreme Court upheld the decision.</p> <p>Phillip Morris appealed to the Supreme Court, arguing that the court had unreasonably exceeded federal guidelines on punitive damages. Phillip Morris also argued that it was unfair to punish the company for its actions toward other smokers who were not parties to the suit.</p>
1,715
5
4
true
majority opinion
vacated/remanded
Economic Activity
1,824
55,446
Winkelman v. Parma City School District
https://api.oyez.org/cases/2006/05-983
05-983
2006
Jacob Winkelman, a minor, by and through his parents and legal guardians, Jeff and Sandee Winkelman, et al.
Parma City School District
<p>Jeff and Sandee Winkelman claimed that Parma City School District failed to give their disabled son Jacob a "free appropriate public education" as required by the Individuals with Disabilities Education Act (IDEA). Despite the Winkelmans' opposition, the school district planned to place Jacob in a public elementary school. After a preliminary school district hearing affirmed Jacob's placement, the Winkelmans placed Jacob in a private school at their own expense and petitioned a federal District Court for reimbursement.</p> <p>The District Court ruled for the School District. On appeal, the U.S. Court of Appeals for the Sixth Circuit dismissed the suit because the Winkelmans lacked a lawyer. The Winkelmans argued that according to the IDEA, "any party aggrieved by the findings" of a preliminary school district hearing may appeal in a federal court. Also, because the IDEA demands active parental involvement in order to enforce proper child placement, the parent should be able to appear in court "pro se" - without a lawyer. The Sixth Circuit rejected both arguments and held that the IDEA does not establish any right of a non-lawyer parent to represent his disabled child in federal court. Non-lawyer parents cannot represent themselves either, the Circuit Court ruled, because the IDEA protects the rights of the child, not the parents.</p>
1,359
7
2
true
majority opinion
reversed/remanded
Civil Rights
1,825
55,445
United States v. Resendiz-Ponce
https://api.oyez.org/cases/2006/05-998
05-998
2006
United States
Juan Resendiz-Ponce
<p>Juan Resendiz-Ponce, a Mexican national, was convicted of kidnapping and deported. When Resendiz-Ponce tried to reenter the U.S. using false identification, he was arrested and indicted for attempting to reenter the country after being deported. Resendiz-Ponce moved to dismiss his indictment because it failed to allege that he had "committed an overt act that was a substantial step toward reentering" - an essential element of the criminal offense. The trial judge denied the motion and the jury convicted Resendiz- Ponce.</p> <p>On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed the trial judge's decision to deny the motion. The Ninth Circuit ruled that because the indictment failed to explicitly mention that Resendiz-Ponce had physically crossed the border and presented false identification, it was insufficient and should be dismissed. The government argued that the omission was "harmless error," a minor mistake that would not invalidate the indictment, but the Circuit Court ruled that the omission was instead a "fatal flaw."</p>
1,065
8
1
true
majority opinion
reversed/remanded
Criminal Procedure
1,826
55,448
Bowles v. Russell
https://api.oyez.org/cases/2006/06-5306
06-5306
2006
Keith Bowles
Harry Russell, Warden
<p>Keith Bowles was convicted of murder. He filed a petition for habeas corpus in federal District Court, and was denied. Bowles did not receive timely notice of the District Court's ruling, so he missed the deadline for appeal. He filed a motion under Federal Rule of Appellate Procedure 4(a)(6) to reopen the appeal period. The District Court granted Bowles's motion, and gave him until February 27, 2004 to file his appeal. However, Rule 4(a)(6) allows only a 14-day extension of the appeal period, which would put the deadline on February 24, 2004. Bowles filed his appeal on February 26 - on time according to the court's deadline, but untimely according to Rule 4(a)(6).</p> <p>The U.S. Court of Appeals for the Sixth Circuit at first declined to dismiss Bowles's appeal. Later, on its own motion, the Sixth Circuit "correct[ed] [its] error" and dismissed the appeal, saying Rule 4(a)(6) "is not susceptible to extension through mistake, courtesy, or grace."</p>
969
5
4
false
majority opinion
affirmed
Judicial Power
1,827
55,447
United Haulers Assocation, Inc. v. Oneida-Herkimer Solid Waste Management Authority
https://api.oyez.org/cases/2006/05-1345
05-1345
2006
United Haulers Association, Inc., et al.
Oneida-Herkimer Solid Waste Management Authority et al.
<p>Oneida and Herkimer counties adopted a local "flow control" ordinance requiring locally-produced garbage to be delivered to local publicly-owned facilities. The United Haulers Association filed suit in federal district court, arguing that by prohibiting the export of waste and preventing waste haulers from using less expensive out-of-state facilities, the ordinance ran afoul of the dormant Commerce Clause. The Supreme Court has held that the Commerce Clause forbids any state law that regulates interstate commerce. The District Court ruled against United Haulers and held that the ordinance was constitutional because it did not discriminate against out-of-state businesses.</p> <p>On appeal, the U.S. Court of Appeals for the Second Circuit affirmed. The Court of Appeals ruled that even if the ordinance imposed a slight burden on interstate commerce, the effect was outweighed by the ordinance's local benefits.</p>
927
6
3
false
majority opinion
affirmed
Economic Activity
1,828
55,450
KSR International Co. v. Teleflex Inc.
https://api.oyez.org/cases/2006/04-1350
04-1350
2006
KSR International Co.
Teleflex Inc. et al.
<p>Teleflex sued KSR International (KSR), alleging that KSR had infringed on its patent for an adjustable gas-pedal system composed of an adjustable accelerator pedal and an electronic throttle control. KSR countered that Teleflex's patent was obvious, and therefore unenforceable. Under 25 U.S.C. Section 103(a), obvious inventions cannot be patented. A federal District Court granted summary judgment for KSR, accepting KSR's argument that the invention was obvious because each of the invention's components existed in previous patents. Anyone with knowledge or experience in the industry, the District Court ruled, would have considered it obvious that the two components could be combined. Teleflex appealed to the Court of Appeals for the Federal Circuit, which reversed the District Court. The Circuit Court found the lower court's analysis incomplete, because the District Court had not applied a full "teaching-suggestion-motivation test." Under this test, in order to label the patent obvious the District Court would have needed to identify the specific "teaching, suggestion, or motivation" that would have led a knowledgeable person to combine the two previously-existing components. KSR appealed to the Supreme Court, arguing that the Circuit Court's test conflicted with Supreme Court precedent and that it would allow too many patents of obvious inventions.</p>
1,378
9
0
true
majority opinion
reversed/remanded
Economic Activity
1,829
55,449
Bell Atlantic Corp. v. Twombly
https://api.oyez.org/cases/2006/05-1126
05-1126
2006
Bell Atlantic Corp. et al.
William Twombly et al.
<p>William Twombly and other consumers brought a class action lawsuit against Bell Atlantic Corp. and other telecommunications companies. Twombly alleged that the companies had violated Section 1 of the Sherman Act by conspiring to end competition among themselves and to stifle new competition. In the suit, Twombly claimed that the companies had agreed not to branch out into and compete in one another's territories, even though the Telecommunications Act of 1996 might have made it relatively inexpensive to do so.</p> <p>The District Court granted Bell Atlantic's motion to dismiss the suit, however, because Twombly had failed to "allege sufficient facts from which a conspiracy can be inferred." In order to sufficiently claim a Section 1 violation, the court held, the plaintiffs needed to establish a "plus factor" - a piece of evidence showing that the defendants' behavior would be against their economic self-interest unless there was a conspiratorial agreement. Twombly had not established a plus factor, the court held, because the companies' defensive behavior could have been motivated by economic factors rather than conspiracy.</p> <p>Twombly appealed to the U.S. Court of Appeals for the Second Circuit, which reversed the lower court. The Second Circuit ruled that Twombly needed only to allege a conspiracy and specific facts that would support a Section 1 violation. Since he had alleged that the companies had engaged in suspicious "parallel conduct" and conspired to preserve monopoly conditions, his claim was sufficient and the suit could proceed.</p>
1,578
7
2
true
majority opinion
reversed/remanded
Economic Activity
1,830
55,452
Watson v. Philip Morris Companies, Inc.
https://api.oyez.org/cases/2006/05-1284
05-1284
2006
Lisa Watson et al.
Philip Morris Companies, Inc., et al.
<p>Lisa Watson filed a class action lawsuit against the tobacco company Philip Morris, claiming that the company had violated Arkansas law by misrepresenting the amount of tar and nicotine in cigarettes branded as "light." Seeking to have the case removed to federal court, Philip Morris invoked 28 U.S.C. 1442(a)(1), which allows removal when a party is sued for actions taken while "acting under" a federal officer. Philip Morris claimed that it was acting under the direct control of regulations promulgated by the Federal Trade Commission (FTC), so 28 U.S.C. 1442(a)(1) applied. After the federal District Court denied Watson's motion to have the case sent back to state court, Watson appealed.</p> <p>The dispute centered on the degree of control exercised by the FTC over Philip Morris. The U.S. Court of Appeals for the Eighth Circuit affirmed the lower court's ruling in favor of Philip Morris, allowing the case to continue in the federal court system. The Eighth Circuit held that the question of whether 28 U.S.C. 1442(a)(1) applies "depends on the detail and specificity of the federal direction of the defendant's activities and whether the government exercises control over the defendant." In the case of the tobacco industry, the Eighth Circuit found "unprecedented" government involvement, including detailed FTC regulations concerning the testing and disclosure of tar and nicotine levels. Therefore, Philip Morris was "acting under a federal officer" and consequently entitled to remove the case to federal court.</p>
1,536
9
0
true
majority opinion
reversed/remanded
Judicial Power
1,831
55,451
Wallace v. Kato
https://api.oyez.org/cases/2006/05-1240
05-1240
2006
Andre Wallace
Chicago Police Officers Kristen Kato and Eugene Roy
<p>In 1994, Andre Wallace was arrested and charged with murder. Two years later he was convicted and sent to prison. Wallace appealed, arguing that the police had arrested him without probable cause and coerced him into confessing to the crime. In 1998, an appeals court agreed that Wallace had been arrested without probable cause and granted him a new trial. Finally, in 2002, the prosecution dropped its case against him. The next year Wallace sued the police officers and the city of Chicago for violating his Fourth Amendment rights through false arrest.</p> <p>The District Court ruled against Wallace, because his suit was time-barred. In Illinois there is a two-year statute of limitations on false-arrest claims. Since Wallace had not brought suit within two years of either his arrest or the time the arrest was declared invalid, his time was up. Wallace appealed to the Seventh Circuit Court of Appeals, arguing that the two-year limit did not begin until his conviction was finally set aside in 2002.</p> <p>The Circuit Court upheld the District Court, ruling against Wallace. The Circuit Court panel acknowledged that other Circuits had failed to agree on the question of when the statute of limitations for a false arrest claim should begin. The Seventh Circuit opted for a clear rule - the two-year limit starts at the time of the arrest, and therefore Wallace's suit was too late</p>
1,400
7
2
false
majority opinion
affirmed
Civil Rights
1,832
55,453
Lopez v. Gonzales
https://api.oyez.org/cases/2006/05-547
05-547
2006
Jose Antonio Lopez
Alberto R. Gonzales, Attorney General
<p>Jose Lopez, a Mexican national living in South Dakota, was convicted of aiding and abetting the possession of cocaine. The crime is a felony under South Dakota law, but only a misdemeanor under the federal Controlled Substances Act.</p> <p>The Immigration and Naturalization Service began proceedings to remove Lopez from the country. Lopez applied for a cancellation of his removal, citing the Immigration and Naturalization Act (INA). The INA allows an alien to avoid removal if he meets certain qualifications and has no prior "aggravated felony" convictions. Lopez argued that he was eligible for cancellation of his removal because his drug offense was only a misdemeanor under federal law.</p> <p>An Immigration Judge denied Lopez's request for cancellation, and the Board of Immigration Appeals affirmed, on the grounds that Lopez had committed an aggravated felony. Lopez then sued the Attorney General and brought his case to the Court of Appeals for the Eighth Circuit. The Circuit Court affirmed the lower courts, ruling that a crime is an aggravated felony under the INA if it is a felony under either federal or state law.</p>
1,143
8
1
true
majority opinion
reversed/remanded
Civil Rights
1,833
55,454
Watters v. Wachovia Bank, N.A.
https://api.oyez.org/cases/2006/05-1342
05-1342
2006
Linda A. Watters, Commissioner, Michigan Office of Insurance and Financial Services
Wachovia Bank, N.A., et al.
<p>Under 12 U.S.C. Section 484(a), states do not have regulatory powers over national banks. In 2001 the federal Office of the Comptroller of Currency (OCC) issued federal regulation 12 C.F.R. 7.4006, which applied 12 U.S.C. Section 484(a) to state-chartered operating subsidiaries of national banks. Wachovia Mortgage was an operating subsidiary of the national bank Wachovia Bank, and was registered with the state of Michigan.</p> <p>When Michigan attempted to exercise its regulatory powers over Wachovia Mortgage, Wachovia Bank sued Watters, a Michigan official, seeking a judgment that Michigan's laws on operating subsidies of national banks were superceded by 12 U.S.C Section 484(a). Michigan argued that the OCC had exceeded the authority given it by Congress by extending the definition of "national bank" to cover state-registered operating subsidiaries. Michigan also argued that the extension of federal authority over state entities like Wachovia Mortgage violates the Tenth Amendment, which reserves to states all powers not delegated to the federal government.</p> <p>The District Court rejected these arguments and ruled for Wachovia, and the U.S. Court of Appeals for the Sixth Circuit affirmed. The Circuit Court found that the decision of the OCC to apply rules for national banks to their operating subsidiaries was a reasonable interpretation of Congress's intent, and therefore entitled to deference under <em>Chevron U.S.A. v. Natural Resources Defense Council</em>. The Sixth Circuit also held that Congress had the power to regulate operating subsidiaries of national banks under the Commerce Clause, so the Tenth Amendment did not reserve that power to the states.</p>
1,697
5
3
false
majority opinion
affirmed
Federalism
1,834
55,455
Abdul-Kabir v. Quarterman
https://api.oyez.org/cases/2006/05-11284
05-11284
2006
Jalil Abdul-Kabir, fka Ted Calvin Cole
Nathaniel Quarterman, Director, Texas Department of Criminal Justice, Correctional Institutions Division
<p>Jalil Abdul-Kabir was convicted of murder and sentenced to death. At his sentencing, Abdul-Kabir presented mitigating evidence of his destructive family background and neurological defects. The jury was instructed to give effect to all mitigating evidence by making yes-or-no determinations on Texas's two "special issues" for capital sentencing: the deliberateness of the crime and the future dangerousness of the criminal. After his sentencing, Abdul-Kabir filed a petition for habeas corpus in federal District Court, arguing that the special issues had not allowed the jury to give full consideration and effect to his mitigating evidence as required by the Supreme Court in <em>Penry v. Johnson</em>. The District Court denied Abdul-Kabir habeas relief, and the U.S. Court of Appeals for the Fifth Circuit affirmed.</p> <p>The Fifth Circuit held that the mitigating evidence was not "constitutionally relevant," and that in any case the jury could have given it consideration as part of the "deliberateness" and "dangerousness" determinations. After the Supreme Court rejected the "constitutional relevance" test, the Fifth Circuit reaffirmed its decision that Abdul-Kabir's mitigating evidence had been given full consideration and effect under the Texas special issues. The case was consolidated with <em>Brewer v. Quarterman</em> No. 05-11287.</p>
1,359
5
4
true
majority opinion
reversed/remanded
Criminal Procedure
1,835
55,456
Parents Involved in Community Schools v. Seattle School District No. 1
https://api.oyez.org/cases/2006/05-908
05-908
2006
Parents Involved In Community Schools
Seattle School District No. 1 et al.
<p>The Seattle School District allowed students to apply to any high school in the District. Since certain schools often became oversubscribed when too many students chose them as their first choice, the District used a system of tiebreakers to decide which students would be admitted to the popular schools. The second most important tiebreaker was a racial factor intended to maintain racial diversity. If the racial demographics of any school's student body deviated by more than a predetermined number of percentage points from those of Seattle's total student population (approximately 40% white and 60% non-white), the racial tiebreaker went into effect. At a particular school either whites or non-whites could be favored for admission depending on which race would bring the racial balance closer to the goal.</p> <p>A non-profit group, Parents Involved in Community Schools (Parents), sued the District, arguing that the racial tiebreaker violated the Equal Protection Clause of the Fourteenth Amendment as well as the Civil Rights Act of 1964 and Washington state law. A federal District Court dismissed the suit, upholding the tiebreaker. On appeal, a three-judge panel the U.S. Court of Appeals for the Ninth Circuit reversed.</p> <p>Under the Supreme Court's precedents on racial classification in higher education, <em>Grutter v. Bollinger</em> and <em>Gratz v. Bollinger</em>, race-based classifications must be directed toward a "compelling government interest" and must be "narrowly tailored" to that interest. Applying these precedents to K-12 education, the Circuit Court found that the tiebreaker scheme was not narrowly tailored. The District then petitioned for an "en banc" ruling by a panel of 11 Ninth Circuit judges. The en banc panel came to the opposite conclusion and upheld the tiebreaker. The majority ruled that the District had a compelling interest in maintaining racial diversity. Applying a test from <em>Grutter</em>, the Circuit Court also ruled that the tiebreaker plan was narrowly tailored, because 1) the District did not employ quotas, 2) the District had considered race-neutral alternatives, 3) the plan caused no undue harm to races, and 4) the plan had an ending point.</p>
2,221
5
4
true
majority opinion
reversed/remanded
Civil Rights
1,836
55,458
Danforth v. Minnesota
https://api.oyez.org/cases/2007/06-8273
06-8273
2007
Stephen Danforth
Minnesota
<p>At Stephen Danforth's trial for sexual abuse of a six-year-old boy, the victim was found incompetent to testify in court, so his videotaped testimony was shown instead. Danforth was convicted and his appeals were unsuccessful. After Danforth's case became final, the Supreme Court ruled in <em>Crawford v. Washington</em> that pre-recorded testimony without the possibility of cross-examination is unconstitutional. Danforth filed a second petition for postconviction relief, seeking to have the <em>Crawford</em> decision applied retroactively to his case. Supreme Court decisions announcing constitutional rules of criminal procedure are applied retroactively only in certain circumstances, which are specified in <em>Teague v. Lane</em>. The state court of appeals declined to retroactively apply <em>Crawford</em>.</p> <p>On appeal to the Minnesota Supreme Court, Danforth raised an alternative argument, claiming that the state court was free to apply a broader standard of retroactivity than the one in <em>Teague</em>. Under Minnesota state retroactivity principles, Danforth argued, the <em>Crawford</em> case met the criteria for retroactive application. In Danforth's interpretation, the <em>Teague</em> standard was mandatory for federal habeas corpus proceedings but not for state postconviction proceedings. The Minnesota Supreme Court rejected Danforth's arguments, ruling that only U.S. Supreme Court decisions determine the proper standard for retroactive application of constitutional criminal procedure. The Supreme Court subsequently ruled in <em>Whorton v. Bockting</em> that <em>Crawford</em> does not apply retroactively under <em>Teague</em>, but it agreed to consider Danforth's alternative argument.</p>
1,732
7
2
true
majority opinion
reversed/remanded
Criminal Procedure
1,837
55,457
Brendlin v. California
https://api.oyez.org/cases/2006/06-8120
06-8120
2006
Bruce Edward Brendlin
California
<p>Police stopped Karen Simeroth's car for having expired registration tabs. Bruce Brendlin, who had a warrant out for his arrest, was riding in the passenger seat. Police found methamphetamine, marijuana, and drug paraphernalia in the car and on Simeroth's person. In a California trial court, Brendlin filed a motion to suppress the evidence obtained at the traffic stop, claiming that the stop was an unreasonable seizure in violation of the Fourth Amendment. The trial court found that Brendlin had never been detained or "seized" within the meaning of the Fourth Amendment. It denied the motion, and Brendlin pleaded guilty to manufacturing methamphetamine. A California Court of Appeal reversed, holding that a traffic stop necessarily results in a Fourth Amendment seizure.</p> <p>The California Supreme Court reversed the Court of Appeal and ruled for California. The court held that the driver of the car is the only one detained in a traffic stop. The movement of any passengers is also stopped as a practical matter, but the court considered this merely a necessary byproduct of the detention of the driver. The court held that Brendlin had been free to leave the scene of the traffic stop or to simply ignore the police. Since he was never "seized," however, he could not claim a violation of the Fourth Amendment.</p>
1,331
9
0
true
majority opinion
vacated/remanded
Criminal Procedure
1,838
55,460
Baze v. Rees
https://api.oyez.org/cases/2007/07-5439
07-5439
2007
Ralph Baze and Thomas C. Bowling
John D. Rees, Commissioner, Kentucky Department of Corrections, et al.
<p>Two Kentucky inmates challenged the state's four-drug lethal injection protocol. The lethal injection method calls for the administration of four drugs: Valium, which relaxes the convict, Sodium Pentathol, which knocks the convict unconscious, Pavulon, which stops his breathing, and potassium chloride, which essentially puts the convict into cardiac arrest and ultimately causes death. The Kentucky Supreme Court held that the death penalty system did not amount to unconstitutional cruel and unusual punishment.</p>
522
7
2
false
plurality opinion
affirmed
Criminal Procedure
1,839
55,459
Federal Express Corporation v. Holowecki
https://api.oyez.org/cases/2007/06-1322
06-1322
2007
Federal Express Corporation
Paul Holowecki et al.
<p>Paul Holowecki and other employees of Federal Express sued the corporation for age discrimination under the Age Discrimination in Employment Act (ADEA). A district court judge dismissed the complaint on the ground that none of the plaintiffs had met the time limits and filing requirements of the ADEA. The ADEA requires that a plaintiff file a "charge" with the Equal Employment Opportunity Commission (EEOC) 60 days prior to filing suit. Upon receiving the charge of discrimination, the EEOC notifies the employer of the accusation, investigates the matter, and offers to mediate. THE EEOC has an "Intake Questionnaire" form and a "Charge" form, but the EEOC regulations state only that "A charge shall be in writing and shall name the prospective respondent and shall generally allege the discriminatory act(s)." One of the plaintiffs completed an intake questionnaire, but the EEOC did not take the steps it should have taken after the filing of a charge. Holowecki sued over 60 days later, but the judge ruled that the intake questionnaire did not qualify as a charge for purposes of the AEDA.</p> <p>The U.S. Court of Appeals for the Second Circuit reversed, allowing Holowecki's suit to go forward. The Second Circuit ruled that the minimal written information required for a charge was contained in the intake questionnaire. The questionnaire also met the ADEA's implicit requirement that the charge be intended to start the process of an ADEA suit. The Second Circuit did not consider it significant that the EEOC did not act on the questionnaire, apparently not believing it to count as a charge. To dismiss a complaint based on the EEOC's inaction would be to hold the plaintiff accountable for the failings of the agency.</p>
1,741
7
2
false
majority opinion
affirmed
Civil Rights
1,840
55,464
Ali v. Achim
https://api.oyez.org/cases/2007/06-1346
06-1346
2007
Ahmed Ali
Deborah Achim et al.
<p>A Somalian immigrant fled ethnic strife in his homeland, coming to the United States with his family in 1999. Two years later, he was involved in a fight during which he injured another man with a box cutter. He pleaded no contest to a felony charge of substantial battery with a dangerous weapon and was sentenced to an 11-month prison term as well as seven years of probation. When he was released, immigration authorities began deportation proceedings because of the felony conviction. The immigration court ruled that the man could stay in the U.S. because he faced retribution if he returned to Somalia, but refused to offer additional forms of protection because it deemed his felony offense "particularly serious." The man appealed, arguing that his crime cannot be considered "particularly serious" because it was not an aggravated felony.</p>
855
0
0
false
dismissal - rule 46
none
null
1,841
55,461
Allison Engine Co., Inc. v. United States ex rel. Sanders
https://api.oyez.org/cases/2007/07-214
07-214
2007
Allison Engine Co., Inc., et al.
United States ex rel. Roger L. Sanders and Roger L. Thacker
<p>Two workers involved in the manufacture of electrical supplies for the Navy's billion-dollar guided missile destroyers brought a whistleblower case alleging that subcontractors performed faulty work. The two charged that the companies employed unqualified workers, installed leaky gearboxes and used defective temperature gauges. After a five-week trial, the district court granted judgment as a matter of law for the companies, concluding that the False Claims Act under which the suits were brought requires that defendants "present" the fraudulent claims to the government. Because the subcontractors actually invoiced the general contractor and not the government, the court ruled that the presentment requirement had not been met. The appeals court reversed, holding that the Act should be liberally construed to discourage private companies from defrauding the government.</p>
886
9
0
true
majority opinion
vacated/remanded
Economic Activity
1,842
55,462
LaRue v. DeWolff, Boberg & Associates, Inc.
https://api.oyez.org/cases/2007/06-856
06-856
2007
James LaRue
DeWolff, Boberg & Associates, Inc., et al.
<p>James LaRue participated in a 401(k) retirement savings plan administered by his employer, the management consulting firm DeWolff, Boberg &amp; Associates. Employee benefit plans are regulated under a federal law, the Employee Retirement Income Security Act of 1974 (ERISA). LaRue sought to exercise his option to make certain changes in his investment plan, but DeWolff neglected to make the changes. LaRue claimed that DeWolff's omission had cost him $150,000, and he sued the firm for breach of fiduciary duty, seeking to recover the money. In response, DeWolff argued that ERISA does not provide for the type of individual monetary award sought by LaRue.</p> <p>Section 502(a)(2) allows plan participants to sue plan administrators for breach of fiduciary duty in order to "make good to such plan any losses to the plan resulting from each such breach." DeWolff argued that LaRue's suit was not of the type contemplated by the text of ERISA because LaRue sued to recover losses caused to his own personal retirement plan rather than suing to vindicate the interests of the plan as a whole. LaRue also invoked Section 502(a)(3), which allows plan participants to sue to obtain "other appropriate equitable relief."</p> <p>The U.S. District Court held that LaRue was not entitled to relief under ERISA, and the U.S. Court of Appeals for the Fourth Circuit affirmed. The Fourth Circuit ruled that Section 502(a)(2) was concerned with protecting entire plans from misuse of plan assets and not with providing recovery for losses suffered by individual accounts. The court also rejected LaRue's Section 502(a)(3) claim. It ruled that the phrase "equitable relief" rarely includes relief in the form of a monetary award and only when the money has been unjustly possessed by the defendant.</p>
1,795
9
0
true
majority opinion
vacated/remanded
Economic Activity
1,843
55,463
Boulware v. United States
https://api.oyez.org/cases/2007/06-1509
06-1509
2007
Michael H. Boulware
United States
<p>Michael H. Boulware founded a coffee and bottled water company known as Hawaiian Isles Enterprises. As his company became profitable in 1987, he began transferring money – a total of $4.5 million – from his company to his mistress. Seven years later, in the midst of a divorce, his mistress refused to return the money when asked, contending that it was a gift. A Hawaii court eventually held that the woman had been holding the money in constructive trust for the company's benefit. Seven years after that, the federal government indicted Boulware for failing to pay taxes on the disputed funds as well as $6 million more that he had received from the company. Boulware argued that under the "return of capital" rule, holding that when unprofitable companies distribute money to shareholders, the money is considered a nontaxable return of capital up to the shareholder's basis in the stock, he owed no taxes. The Ninth Circuit rejected that argument.</p>
960
9
0
true
majority opinion
vacated/remanded
Criminal Procedure
1,844
55,465
Ali v. Federal Bureau of Prisons
https://api.oyez.org/cases/2007/06-9130
06-9130
2007
Abdus-Shahid M.S. Ali
Federal Bureau of Prisons et al.
<p>Before his transfer to a new prison, prisoner Abdus-Shahid M. S. Ali temporarily left his two bags of possessions with a police officer. When the bags arrived, Ali noticed that several items were missing. He filed an administrative tort claim with the Bureau of Prisons seeking to recover the items. After the claim was denied, he brought his case to U.S. District Court. The court dismissed the case for lack of jurisdiction, ruling that the government had immunity from the lawsuit under the Federal Tort Claims Act (FTCA). The FTCA establishes a general waiver of sovereign immunity for tort claims against the government, but it also makes several exceptions to the waiver. One exception is for "[a]ny claim arising in respect of [...] the detention of any goods, merchandise, or other property by any officer of customs or excise or any other law enforcement officer." Ali argued that in context the phrase "other law enforcement officer" referred only to officers working in customs and related activities, but the court applied the exception to any detention of goods by any law enforcement officer.</p> <p>The U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of Ali's claim. It ruled that the phrase "any other law enforcement officer" in the FTCA was not merely a supplementary catch-all relating to the government's immunity in tax collection and customs situations. Rather, it was itself a broad grant of sovereign immunity covering any instance of detention of goods by law enforcement officers.</p>
1,536
5
4
false
majority opinion
affirmed
Economic Activity
1,845
55,466
United States v. Ressam
https://api.oyez.org/cases/2007/07-455
07-455
2007
United States
Ahmed Ressam
<p>In 1999, Ahmed Ressam, the so-called "Millennium Bomber," was arrested attempting to cross the Canadian-U.S. border in a rental car loaded with explosives and other bomb-making materials. Ressam planned to detonate the explosives at Los Angeles International Airport on New Year's Eve. Ressam was charged with several crimes, including carrying an explosive device during the commission of a felony under 18 U.S.C. Section 844. The felony charge was lying to a customs agent.</p> <p>Ressam argued, and the U.S. Court of Appeals for the Ninth Circuit agreed, that the statute required the explosive device to be carried in relation to the underlying felony and, therefore, should not be applied to Ressam in this case. The Ninth Circuit noted Congressional amendment of a substantially similar statute to include such "in relation to" language, indicating the legislature's intent that a connection between the explosives and the underlying felony is indispensable to the claim. The government, noting the case's importance in the realm of terror prosecutions, urged the Court to grant certiorari based on decisions reaching the opposite conclusion in both the Third and Fifth Circuits.</p>
1,193
8
1
true
majority opinion
reversed
Criminal Procedure
1,846
55,468
Rowe v. New Hampshire Motor Transport Association
https://api.oyez.org/cases/2007/06-457
06-457
2007
G. Steven Rowe, Attorney General of Maine
New Hampshire Motor Transport Association et al.
<p>In an effort to address the problem of tobacco use by minors, the Maine legislature passed the Tobacco Delivery Law, which imposes requirements on air and motor carriers that transport tobacco products. One provision of the law requires tobacco retailers to only use carriers that verify the age of each tobacco purchaser, and another provision requires that carriers ensure that no tobacco is shipped to unlicensed retailers. The New Hampshire Motor Transport Association sued, arguing that the state law was preempted by a federal law, the Federal Aviation Administration Authorization Act of 1994 (FAAAA). The preemption provision of the FAAAA prohibits state from enacting laws "related to" the prices, routes, or services of air and motor carriers. The Association argued that the Tobacco Delivery Law placed such a burden on the delivery procedures of carriers that significantly affected their prices and services. The state countered that the FAAAA was only meant to preempt traditional economic regulation by states, and therefore laws enacted pursuant to the state's police power - the power of a state to regulate for the health, safety, and welfare of its citizens - were permissible. The U.S. District Court ruled that the law was preempted by the FAAAA.</p> <p>The U.S. Court of Appeals for the First Circuit affirmed the lower court. The First Circuit held that a police power exception to the general rule of preemption would be far too broad and was not intended by Congress. Maine could validly ban all unlicensed tobacco products within its borders, but the FAAAA prohibited the state from implementing this goal by imposing requirements on carriers that significantly alter their delivery procedures.</p>
1,728
9
0
false
majority opinion
affirmed
Federalism
1,847
55,467
Munaf v. Geren
https://api.oyez.org/cases/2007/06-1666
06-1666
2007
Mohammad Munaf et al.
Pete Geren, Secretary of the Army, et al.
<p>In 2005, Mohammad Munaf was arrested on suspicion of kidnapping by U.S. military officers acting as part of a multinational force in Iraq. Munaf's sister petitioned on his behalf for habeas corpus in the U.S. District Court in the District of Columbia. Soon after the petition was filed, Munaf was informed that he would be tried in an Iraqi court and transferred to Iraqi custody if convicted. Munaf filed a temporary restraining order attempting to block custody transfer.</p> <p>After the Iraqi court sentenced him to death and the district court dismissed his case for lack of jurisdiction, Munaf appealed to the U.S. Court of Appeals for the D.C. Circuit which granted an injunction against the transfer. However, the D.C. Circuit, like the district court, eventually concluded that it did not have jurisdiction over Munaf's claim, basing its decision largely on the Court's ruling in <em>Hirota v. MacArthur</em> 338 U.S. 197 (1948). That decision prohibited Japanese citizens held abroad by U.S. troops from filing habeas petitions to challenge sentences handed down by a military tribunal sitting in Japan but including U.S. military personnel. Petitioner urges the Court to set aside Hirota and its ruling and to base its reasoning on a string of cases reaching the opposite result. The case will be consolidated and heard along with another D.C. case, Geren v. Omar, 07-394, in which the D.C. Circuit allowed a habeas petition by a U.S. citizen held in Iraq because he had not yet been charged or convicted by an Iraqi court.</p>
1,543
9
0
false
majority opinion
vacated/remanded
Criminal Procedure
1,848
55,470
Rothgery v. Gillespie County
https://api.oyez.org/cases/2007/07-440
07-440
2007
Walter A. Rothgery
Gillespie County, Texas
<p>Walter Rothgery was arrested in Texas as a felon in possession of a firearm. Rothgery was taken before a judge for processing and, upon learning that seeking legal assistance would delay the proceedings, waived his Sixth Amendment right to counsel. No prosecutor was present at this hearing. Rothgery posted bail and was released, but was rearrested after a grand jury indictment several months later hiked his bail to a sum he could not afford. Throughout this entire period Rothgery continued to pursue legal counsel and only obtained such counsel approximately one week after the grand jury indictment. Rothgery's attorney produced evidence that Rothgery was in fact not a felon and he was released from custody. Rothgery brought suit against Gillespie County, TX for violating his civil rights by not appointing counsel as required under the Sixth Amendment.</p> <p>Both the district court and the Fifth Circuit rejected his claim, the Fifth Circuit stating that Rothgery's Sixth Amendment rights were not implicated because no prosecutor was present at the initial hearing. In his petition for certiorari, Rothgery argued that both federal and state case law indicate that the Sixth Amendment right to counsel applies to any hearing where a defendant is advised of his rights and the charges against him, regardless of whether or not a prosecutor is present.</p>
1,371
8
1
true
majority opinion
vacated/remanded
Civil Rights
1,849
55,469
Davis v. Federal Election Commission
https://api.oyez.org/cases/2007/07-320
07-320
2007
Jack Davis
Federal Election Commission
<p>Jack Davis, a wealthy Democratic candidate for Congress from New York's 26th Congressional District, brought this claim challenging the constitutionality of the so-called 'Millionaire's Amendment' to the 2002 campaign finance law. Davis argued in the district court that the law, which basically raises the contribution cap for individuals running against self-financed candidates, violated the First Amendment and the Equal Protection principle implicit in the Fifth Amendment. The district court rejected both of these claims, stating first that the law did not implicate the First Amendment because it did not impede Davis' ability to spend money in support of his message, noting that it actually led to a higher level of speech in the race overall. The district court similarly rejected Davis' Fifth Amendment claim, reasoning that although Davis may have been held to higher reporting standards than his opponent, his disproportionate wealth meant that the two candidates were not similarly situated and, therefore, the Equal Protection Clause did not apply. The campaign finance law allows direct appeal to the Court, which will consider whether Davis has standing to bring the First Amendment claim before deciding the case on the merits.</p>
1,254
5
4
true
majority opinion
reversed/remanded
First Amendment
1,850
55,471
Kentucky Retirement Systems v. EEOC
https://api.oyez.org/cases/2007/06-1037
06-1037
2007
Kentucky Retirement Systems et al.
Equal Employment Opportunity Commission
<p>Charles Lickteig is a deputy sheriff in Kentucky. Because he is a hazardous duty worker, he is eligible to retire at age 55. Kentucky Retirement Systems offers a two-tier calculation of so-called "disability retirement benefits." If hazardous duty workers like Lickteig opt to keep working and then become disabled, they receive only their scheduled retirement benefits. In contrast, workers who become disabled before reaching age 55 receive payments that reflect not only their actual years of service but the number of years remaining until they would have reached 55. In effect, if two workers were otherwise identical, the one who retired on disability before 55 would always get benefits equal to or greater than those of the post-55 retiree.</p> <p>Lickteig decided against retirement at 55. Six years later, he became disabled because of "a deteriorating vertebra, arthritis, nerve damage, and Parkinson's disease," and stopped working. When he applied for disability retirement benefits, he received word that he was eligible only for standard retirement.</p> <p>The Equal Employment Opportunity Commission argued unsuccessfully in federal district court that the two-tier system violated the Age Discrimination in Employment Act (ADEA). The U.S. Court of Appeals for the Sixth Circuit affirmed. The appellate court reheard the case <em>en banc</em> and reversed, holding that the simple act of treating younger disabled retirees better than older ones was sufficient to make out a prima facie ADEA violation.</p>
1,526
5
4
true
majority opinion
reversed
Civil Rights
1,851
55,472
Meacham v. Knolls Atomic Power Laboratory
https://api.oyez.org/cases/2007/06-1505
06-1505
2007
Clifford B. Meacham et al.
Knolls Atomic Power Laboratory, aka KAPL, Inc., et al.
<p>When the New York-based federal research laboratory Knolls Atomic Power Lab instituted a downsizing program, it asked supervisors to rank employees based on three factors: performance, flexibility, and the criticality of their skills, and then to add points for years of service in order to determine who would be dismissed. Of the thirty-one employees who were let go, all but one were over the age of forty. Twenty-six of these dismissed employees filed suit against Knolls for age discrimination in violation of the Age Discrimination in Employment Act (ADEA). A jury found for the employees and the U.S. Court of Appeals for the Second Circuit affirmed.</p> <p>However the U.S. Supreme Court vacated the judgment, relying on its 2005 decision in <em>Smith v. City of Jackson</em> to hold that "an employer is not liable under the ADEA so long as the challenged employment action, in relying on specific non-age factors, constitutes a reasonable means to the employer's legitimate goals." On remand, the Second Circuit vacated its previous decision and held that the employees had failed to carry their burden of proving the evaluation system unreasonable. In seeking Supreme Court review, the employees argued that it should be Knolls, not them, who must prove the reasonableness of an action that would otherwise be prohibited.</p>
1,340
7
1
true
majority opinion
vacated/remanded
Civil Rights
1,852
55,473
Plains Commerce Bank v. Long Family Land & Cattle Co.
https://api.oyez.org/cases/2007/07-411
07-411
2007
Plains Commerce Bank
Long Family Land & Cattle Co., Inc.
<p>The Long family, members of the Sioux nation, owned a cattle company that had been doing business with the Plains Commerce Bank for seven years when the family patriarch died. Because Plains Commerce was reluctant to grant operating loans to younger generation family members, it struck a deal with the Longs agreeing to provide the operating loans if the Longs deeded their farmland and house to the bank. According to the Longs the bank never followed through on its promise to provide the operating loans, and after the bank attempted to foreclose on the land the Longs brought suit in a local tribal court seeking a temporary restraining order blocking the land transfer as well as charging the bank with tortuous discrimination. The tribal court returned an award of $700,000 for the Longs, after which Plains Commerce filed suit in federal district court claiming that the tribal court had improperly exercised jurisdiction over the case.</p> <p>The district court decided that the tribal court had jurisdiction over the claim, and the U.S. Court of Appeals for the Eighth Circuit affirmed. In seeking Supreme Court review, Plains Commerce argued that the tribal court should not have had jurisdiction, and the Eighth Circuit erred in deciding so, because the claim did not fit into one of the exceptions granting such jurisdiction set forth by the Supreme Court in _Montana v. U.S. _ On the other hand, the Longs argued that federal courts whose geographic reach encompasses tribal lands have repeatedly allowed tribal courts to adjudicate civil suits against non-members who voluntarily did business with members.</p>
1,629
5
4
true
majority opinion
reversed
Civil Rights
1,853
55,477
Snyder v. Louisiana
https://api.oyez.org/cases/2007/06-10119
06-10119
2007
Allen Snyder
State of Louisiana
<p>In capital murder trial of Allen Snyder, an African-American, the prosecution used peremptory (automatic) challenges to dismiss five African-American prospective jurors. This resulted in Snyder being tried by an all-white jury, which found him guilty and approved the death penalty. The defense argued that the prosecution's striking of the black jurors was racial discrimination in violation of the Equal Protection Clause, according to the standard set forth by the Supreme Court in <em>Batson v. Kentucky</em>. As part of its case for the prosecution's alleged discriminatory intent, the defense cited two of the prosecutor's statements comparing the case to the O.J. Simpson murder trial. After having indirectly referred to the Simpson trial before jury selection, the prosecutor had invoked the case again during the sentencing phase, comparing aspects of Snyder's case to Simpson's and noting that the latter defendant "got away with it." The trial court applied the <em>Batson</em> framework and denied the defense's challenges.</p> <p>On appeal, the Louisiana Supreme Court upheld the trial court, ruling that the trial judge had not acted unreasonably when he accepted the prosecution's race-neutral justifications for the dismissals of the black jurors. The court ruled that the O.J. Simpson references were harmless comparisons made in the course of a rebuttal, and it noted that the prosecution had not mentioned Simpson's or Snyder's race. When the Supreme Court instructed the state court to reconsider the case in light of <em>Miller-El v. Dretke</em>, which requires that courts consider the totality of the circumstances when evaluating discriminatory intent, the court affirmed the trial court a second time.</p>
1,735
7
2
true
majority opinion
reversed/remanded
Civil Rights
1,854
55,475
Riegel v. Medtronic, Inc.
https://api.oyez.org/cases/2007/06-179
06-179
2007
Donna S. Riegel, individually and as administrator of the Estate of Charles R. Riegel
Medtronic, Inc.
<p>During Charles Riegel's angioplasty, his surgeon used an Evergreen Balloon Catheter to dilate his coronary artery. The catheter burst, causing extreme complications. Riegel sued the manufacturer, Medtronic, for negligence in the design, manufacture, and labeling of the device. Medtronic argued that Riegel could not bring these state-law negligence claims because they were preempted by Section 360k(a) of the Medical Device Amendments (MDA) to the Food, Drug, and Cosmetic Act. The MDA establishes a federal regulatory process for ensuring the safety of medical devices, and it provides that no state may set requirements that differ from or add to the federal ones. The District Court dismissed Riegel's claims as preempted by the MDA.</p> <p>The U.S. Court of Appeals for the Second Circuit agreed that the suits based on medical devices like the Evergreen Balloon Catheter are preempted by the MDA. The catheter had been through the exceptionally rigorous "premarket approval" (PMA) process, by which federal regulators ensured that it met federal requirements. To allow state common-law suits for PMA-approved devices, the court ruled, would be to add a state requirement to the regulatory process despite the MDA's preemption clause.</p>
1,248
8
1
false
majority opinion
affirmed
Federalism
1,855
55,474
Kimbrough v. United States
https://api.oyez.org/cases/2007/06-6330
06-6330
2007
Derrick Kimbrough
United States
<p>In 1986, during the Reagan administration's anti-drug initiative, Congress enacted a federal sentencing policy of punishing crimes involving crack cocaine at a 100-to-1 ratio compared to crimes involving powder cocaine. For example, the sentencing guidelines prescribe the same sentence for a defendant convicted of dealing 500 grams of powder cocaine as they do for a defendant convicted of dealing only five grams of crack cocaine. Congress declined to repeal the 100-to-1 ratio despite the U.S. Sentencing Commission's contention that the ratio led to exaggerated sentences for crack dealers.</p> <p>Derrick Kimbrough pleaded guilty to distributing fifty or more grams of crack cocaine, along with other drug-and firearm-related offenses. The federal sentencing guidelines prescribed a sentence of between 19 and 22.5 years, but the district court judge considered this sentence "ridiculous." Citing the Sentencing Commission's reports, the judge decided to depart from the 100-to-1 ratio and hand down a sentence of 15 years. Since the Supreme Court's decision in <em>United States v. Booker</em> the sentencing guidelines have been advisory only, but the guidelines range is still among the factors a court must consider before handing down a reasonable sentence.</p> <p>On appeal, the U.S. Court of Appeals for the Fourth Circuit rejected the below-guidelines sentence as unreasonable. The Fourth Circuit ruled that trial judges act unreasonably when they depart from the guidelines on the basis of a disagreement with a congressional sentencing policy. Therefore, judges cannot hand down below-guidelines sentences merely in order to avoid the sentencing disparity caused by the 100-to-1 ratio.</p>
1,709
7
2
true
majority opinion
reversed/remanded
Criminal Procedure
1,856
55,479
Begay v. United States
https://api.oyez.org/cases/2007/06-11543
06-11543
2007
Larry Begay
United States
<p>In 2004, New Mexico resident Larry Begay was arrested after brandishing and unsuccessfully shooting a rifle while begging his sister for money. Begay pleaded guilty to possessing the rifle. Prior to the firearm arrest, Begay had been convicted twelve times of driving while intoxicated. Under New Mexico law, each DWI conviction after the first three were considered felonies. The court concluded that the DWI convictions were violent felonies, triggering the federal career criminal law's 15-year mandatory minimum sentence. A deeply divided court of appeals panel affirmed the decision to treat the DWIs as violent felonies.</p>
634
6
3
true
majority opinion
reversed/remanded
Criminal Procedure
1,857
55,478
Gómez-Pérez v. Potter
https://api.oyez.org/cases/2007/06-1321
06-1321
2007
Myrna Gomez-Perez
John E. Potter, Postmaster General
<p>Myrna Gómez-Pérez worked as a clerk for the United States Postal Service (USPS) in Puerto Rico. Gómez alleged that she was subject to retaliatory treatment after filing an age discrimination complaint against her supervisors under section 15 of the Age Discrimination in Employment Act (ADEA). A federal district court granted summary judgment to the USPS on the ground that the United States had not waived sovereign immunity as to retaliation claims under the ADEA.</p> <p>Gómez appealed to the United States Court of Appeals in the First Circuit. It held that the USPS and Potter have waived sovereign immunity with respect to ADEA suits, but that Section 15 of the ADEA does not provide a cause of action for retaliation by federal employers.</p>
754
6
3
true
majority opinion
reversed/remanded
Civil Rights
1,858
55,480
Metropolitan Life Ins. Co. v. Glenn
https://api.oyez.org/cases/2007/06-923
06-923
2007
Metropolitan Life Insurance Company et al.
Wanda Glenn
<p>Wanda Glenn, a long-time employee of Sears and manager of its women's department, was covered by the company's long-term disability plan. In 2000, Glenn took medical leave from Sears based on an ailing heart condition and submitted a disability claim under her ERISA plan. Metlife, the insurance carrier, approved the claim and told Glenn to seek social security payments which could then be deducted from her Metlife payments. However, after an administrative law judge determined, based in part on information provided by Metlife, that Glenn was disabled and eligible for social security payments, Metlife revised its own opinion and decided Glenn was no longer eligible for disability benefits.</p> <p>Glenn brought suit against Metlife in district court, where Metlife's change of heart was vindicated, however the U.S. Court of Appeals for the Sixth Circuit reversed. In making its decision, the Sixth Circuit took into account Metlife's dual role as both the entity determining when disability awards should be paid out as well as the entity actually funding those payments, noting the possible conflicts of interest that could arise based on this arrangement. In seeking Supreme Court review, Metlife drew attention to circuit splits on the issue of whether these conflicts should be taken into account in determining the validity of Metlife's decisions on disability. In addition to the conflict of interest argument, Glenn pointed out that Metlife's flip-flop did not take into account certain of Glenn's doctor evaluations and that Metlife's representations to the administrative judge were at odds with its own eventual determination that she was not disabled.</p>
1,679
6
3
false
majority opinion
affirmed
Economic Activity
1,859
55,481
MeadWestvaco Corp. v. Illinois Department of Revenue
https://api.oyez.org/cases/2007/06-1413
06-1413
2007
MeadWestvaco Corp., successor in interest to Mead Corp.
Illinois Department of Revenue et al.
<p>MeadWestvaco, an Ohio company, sold its lucrative Lexis/Nexis division for a $1 billion profit in 1994. Illinois attempted to claim a portion of that profit when collecting taxes from MeadWestvaco for doing business in the state. Illinois argued that Lexis/Nexis was an "operational" part of Mead's business and therefore subject to taxation outside Mead's home state. Mead countered that Lexis/Nexis was merely an "investment," whose sale was immune from taxation from outside jurisdictions. The trial court found that the division was key to Mead's operations, and therefore taxable, and the Illinois Appellate Court agreed.</p>
634
9
0
false
majority opinion
vacated/remanded
Economic Activity
1,860
55,484
Wright v. Van Patten
https://api.oyez.org/cases/2007/07-212
07-212
2007
Randall Wright, Sheriff, Shawano County, Wisconsin
Joseph L. Van Patten
<p>When Joseph Van Patten pled no contest to a charge of first-degree reckless homicide in a Wisconsin state court, his lawyer was not at his side during the hearing. Rather, the lawyer was linked to the courtroom by speakerphone. After the court imposed the maximum penalty of 25 years on Van Patten, he retained new counsel and moved in the Wisconsin Court of Appeals to have his plea withdrawn. Van Patten claimed that his lawyer's failure to appear in person and the decision to conduct the plea hearing via speakerphone violated his Sixth Amendment right to counsel.</p> <p>The Wisconsin appellate court, applying the Court's 1984 ruling in <em>Strickland</em>, concluded that Van Patten's counsel's representation was not "deficient or prejudicial" and denied the motion. Van Patten then filed a petition for habeas corpus in federal court. The district court denied the petition, but the U.S. Court of Appeals for the Seventh Circuit reversed, holding that Van Patten's claim should have been analyzed under the Court's 1984 decision in <em>Cronic</em>, not <em>Strickland</em>, and came out in Van Patten's favor. The case came to the Court for a resolution of this conflicting case law.</p>
1,200
9
0
true
per curiam
reversed/remanded
Criminal Procedure
1,861
55,483
Warner-Lambert Co. v. Kent
https://api.oyez.org/cases/2007/06-1498
06-1498
2007
Warner-Lambert Co., LLC, et al.
Kimberly Kent et al.
<p>A group of Michigan residents who were injured after taking Warner- Lambert's Rezulin diabetes drug sued the company in Michigan state court. The plaintiffs invoked a Michigan tort reform statue immunizing drug makers' liability for FDA-approved products unless the drug makers made misrepresentations to the agency. The federal district court that eventually heard the case dismissed it, ruling that the Michigan "fraud on the FDA" cause of action was preempted by a federal law that empowered the FDA itself to punish misrepresentations. The appeals court reversed, reasoning that the Michigan law did not provide retribution for misrepresentations themselves, but merely created a window for consumers to bring product liability claims where the product reached the market solely through the manufacturer's chicanery.</p>
828
4
4
false
equally divided
affirmed
Federalism
1,862
55,482
Medellin v. Texas
https://api.oyez.org/cases/2007/06-984
06-984
2007
Jose Ernesto Medellin
State of Texas
<p>Jose Medellin, a Mexican national, was convicted and sentenced to death for participating in the gang rape and murder of two teenage girls in Houston. Medellin raised a post-conviction challenge arguing that the state had violated his rights under the Vienna Convention, a treaty to which the United States is a party. Article 36 of the Vienna Convention gives any foreign national detained for a crime the right to contact his consulate. After his petition was ultimately dismissed by the Supreme Court (see <em>Medellin v. Dretke</em> ), Medellin's case returned to the Texas Court of Criminal Appeals. Medellin's argument rested in part on a ruling of the International Court of Justice (ICJ) holding that the U.S. had violated the Vienna Convention rights of 51 Mexican nationals (including Medellin) and that their convictions must be reconsidered. Medellin argued that the Vienna Convention granted him an individual right that state courts must respect, a possibility left open by the Supreme Court's 2006 decision in <em>Sanchez-Llamas v. Oregon</em>. Medellin also cited a memorandum from the President of the United States that instructed state courts to comply with the ICJ's rulings by rehearing the cases. Medellin argued that the Constitution gives the President broad power to ensure that treaties are enforced, and that this power extends to the treatment of treaties in state court proceedings.</p> <p>The Texas Court of Criminal Appeals rejected each of Medellin's arguments and dismissed his petition. The court interpreted <em>Sanchez-Llamas</em> as standing for the principle that rulings of the ICJ are not binding on state courts. The Texas court stood by its position that allowing Medellin to raise the Vienna Convention issue after his trial would violate state procedural rules, and that those rules were not supplanted by the Convention. The President had no authority to order the enforcement in state court of an ICJ ruling, because that would imply a law-making power not allocated to him by the Constitution.</p>
2,048
6
3
false
majority opinion
affirmed
Federalism
1,863
55,485
Knight v. Commissioner of Internal Revenue
https://api.oyez.org/cases/2007/06-1286
06-1286
2007
Michael J. Knight, Trustee of William L. Rudkin Testamentary Trust
Commissioner of Internal Revenue
<p>Trustee Michael J. Knight hired a firm to provide investment-management advice to the William L. Rudkin Testamentary Trust. The Trust deducted all of the fees paid for the investment-advice service from its tax return, but the IRS rejected the deduction. A provision in 26 U.S.C. 67(e) allows trusts to fully deduct certain administrative costs, but the IRS maintained that fees for investment-advice services fall outside the statute's scope. The tax court agreed with the IRS and ruled the fees nondeductible. Federal Courts of Appeals had come to opposite conclusions on the question.</p> <p>On appeal, the U.S. Court of Appeals for the Second Circuit affirmed the tax court. The court cited Section 67(e)'s requirement that a trust's fees are only fully deductible when they "would not have been incurred if the property were not held in such trust." The provision was meant to exempt special administrative expenses that are incurred by trusts. Therefore, the court ruled, costs that could possibly be incurred by individual taxpayers as well as trusts were never deductible in full. Since an individual could pay for investment-advice services, and since the individual's payment would not be fully deductable, Section 67(e) did not exempt a trust's payment for the same services.</p>
1,294
9
0
false
majority opinion
affirmed
Federal Taxation
1,864
55,486
Klein & Co. Futures, Inc. v. Board of Trade of the City of New York
https://api.oyez.org/cases/2007/06-1265
06-1265
2007
Klein & Co. Futures, Inc.
Board of Trade of the City of New York et al.
<p>In his role as chairman of a settlement committee of the Board of Trade of the City of New York, Norman Eisler allegedly manipulated the daily settlement prices of commodities futures in order to conceal bad investments. During this period Eisler's company purchased futures contracts through its broker, the commodity futures merchant Klein &amp; Co. Futures, Inc., but the alleged price manipulation distorted Klein's appraisal of Eisler's ability to pay. When the scheme unravelled, Eisler's company could not meet its obligations and Klein was forced to absorb the loss.</p> <p>Klein sued Eisler and the Board of Trade under Section 22 of the Commodities Exchange Act (CEA), claiming that the Board of Trade failed to enforce rules that would have prevented the manipulation. The CEA requires boards of trade to set rules governing the market, and Section 22 allows private parties to sue for failure to enforce the rules as long as the party was "engaged in any transaction" subject to the board's rules.</p> <p>The U.S. District Court dismissed Klein's claim for lack of standing to sue, and the U.S. Court of Appeals for the Second Circuit affirmed. The Second Circuit interpreted Section 22 as including buyers and sellers of futures contracts but excluding the commodity futures merchants who conduct the actual trades on behalf of their customers. The court ruled that Klein's financial loss was not sufficient to grant it standing, because the loss was suffered in the aftermath of the futures trading and not during the trading itself.</p>
1,555
9
0
false
dismissal - rule 46
none
null
1,865
55,489
Florida Department of Revenue v. Piccadilly Cafeterias, Inc.
https://api.oyez.org/cases/2007/07-312
07-312
2007
Florida Department of Revenue
Piccadilly Cafeterias, Inc.
<p>In 2003, Piccadilly Cafeterias filed a Chapter 11 Bankruptcy petition in federal court in Florida asking the bankruptcy court for permission to auction off its assets in order to fund a reorganization plan. Piccadilly sought a tax exemption under 11 U.S.C. 1146(c) which states that certain asset transfers "under a [confirmed Chapter 11] plan may not be taxed under any law imposing a stamp tax or similar tax." Florida vehemently opposed this exemption and sought to collect $32,000 in taxes from Piccadilly.</p> <p>The bankruptcy court, the district court, and the U.S. Court of Appeals for the Eleventh Circuit all found in favor of Piccadilly, holding that 11 U.S.C. 1146(c) allowed courts to exempt from taxes pre-confirmation asset sales that were essential to the completion of a reorganization plan. In urging the Court to grant certiorari, Florida pointed to both Third and Fourth Circuit decisions holding that such pre-confirmation asset sales were subject to state taxation, while Piccadilly Cafeterias contended that these so-called "circuit splits" only involve a small handful of cases and require no resolution by the Court.</p>
1,149
7
2
true
majority opinion
reversed/remanded
Economic Activity
1,866
55,488
Crawford v. Marion County Election Board
https://api.oyez.org/cases/2007/07-21
07-21
2007
William Crawford et al.
Marion County Election Board et al.
<p>In 2005, the Indiana Legislature passed a law requiring all voters who cast a ballot in person to present a photo ID issued by the United States or the State of Indiana. Plaintiffs including the local Democratic Party and interest groups representing minority and elderly citizens argued that the law constituted an undue burden on the right to vote. At trial, the plaintiffs did not produce any witnesses who claimed they would be unable to meet the law's requirements. The district court and the court of appeals both upheld the law. However, the three-judge appellate panel was deeply divided. Dissenting Judge Terrence Evans claimed that the law was a thinly-veiled attempt to dampen turnout by those likely to vote for Democratic candidates.</p>
754
6
3
false
majority opinion
affirmed
Civil Rights
1,867
55,487
Exxon Shipping Co. v. Baker
https://api.oyez.org/cases/2007/07-219
07-219
2007
Exxon Shipping Company et al.
Grant Baker et al.
<p>The Exxon Valdez supertanker ran aground in Alaska's Prince William Sound in 1989 while under the command of Joseph Hazelwood, a relapsed alcoholic. Exxon knew that Hazelwood had resumed drinking but did not relieve him of his post, and the ship eventually spilled 11 million gallons of oil into the ecologically sensitive sound. The jury calculated compensatory damages at $287 million, and then awarded $5 billion in punitive damages. The punitive award has been reviewed three times by the Ninth Circuit Court of Appeals, which ultimately settled on a $2.5 billion figure. In a dissent from the full court's denial of rehearing in the third review of the award, Judge Alex Kozinski posited that any award, no matter its size, violated the maritime law rule that a ship owner need not pay for the reckless actions of an employee.</p>
839
5
3
true
majority opinion
vacated/remanded
Economic Activity
1,868
55,491
Dada v. Mukasey
https://api.oyez.org/cases/2007/06-1181
06-1181
2007
Samson Taiwo Dada
Michael B. Mukasey, Attorney General
<p>Samson Dada, a Nigerian citizen, entered the United States in 1998 and overstayed his temporary visa. Dada married a U.S. citizen which made him eligible for permanent residence under the Immigration and Naturalization Act. Dada's wife failed to provide the required documentation. In 2004 the government found Dada removable. An immigration judge granted Dada's request for voluntary departure. Before the window to leave the country closed, Dada filed a motion to reopen his removal proceedings. In so doing, he asked that the voluntary departure order be withdrawn, to avoid the 10-year bar on future re-entry that accompanies a failure to leave the country within the allotted time. The Bureau of Immigration Affairs denied the request.</p> <p>Dada appealed to the United States Court of Appeals for the Fifth Circuit. It upheld the denial. Because Dada's voluntary departure period had expired, the appeals court found Dada subject to the 10-year bar on future re-entry.</p>
983
5
4
true
majority opinion
reversed/remanded
Civil Rights
1,869
55,492
Allen v. Siebert
https://api.oyez.org/cases/2007/06-1680
06-1680
2007
Richard F. Allen, Commissioner, Alabama Department of Corrections
Daniel Siebert
<p>Daniel Siebert was convicted of the murder of Linda Jarman and sentenced to death by electrocution in 1989. His conviction was confirmed on appeal, and Siebert’s petition for a writ of certiorari to the Supreme Court was denied in 1990. In 1992, Siebert filed a petition for state post-conviction relief that was denied because it was filed after the two-year statute of limitations period. In 2001, Siebert filed a federal writ of habeas corpus that was denied because the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) has a one-year statute of limitation for filing a federal writ of habeas corpus. Siebert appealed to U.S. Court of Appeals for the Eleventh Circuit and argued that the statute of limitations should not run while his “properly filed” state post-conviction relief was pending. The appellate court determined that the state statute of limitations was not jurisdictional and the state courts could have granted Siebert’s petition, so his petition for state post-conviction relief was “properly filed” and should have prevented the AEDPA’s statute of limitations from running. The appellate court remanded the case for consideration of the petition on the merits. While that review was pending, the Supreme Court decided <em>Pace v. DiGuglielmo</em>, in which the Court held that a petition for state post-conviction relief that was determined to be untimely did not halt the running of the AEDPA’s statute of limitations. Therefore, the district court again rejected Siebert’s petition. The appellate again remanded by holding that the state statute of limitations in this case was non-jurisdictional, and therefore <em>Pace</em> did not apply.</p>
1,684
7
2
true
per curiam
reversed/remanded
Judicial Power
1,870
55,490
District of Columbia v. Heller
https://api.oyez.org/cases/2007/07-290
07-290
2007
District of Columbia et al.
Dick Anthony Heller
<p>Provisions of the District of Columbia Code made it illegal to carry an unregistered firearm and prohibited the registration of handguns, though the chief of police could issue one-year licenses for handguns. The Code also contained provisions that required owners of lawfully registered firearms to keep them unloaded and disassembled or bound by a trigger lock or other similar device unless the firearms were located in a place of business or being used for legal recreational activities.</p> <p>Dick Anthony Heller was a D.C. special police officer who was authorized to carry a handgun while on duty. He applied for a one-year license for a handgun he wished to keep at home, but his application was denied. Heller sued the District of Columbia. He sought an injunction against the enforcement of the relevant parts of the Code and argued that they violated his Second Amendment right to keep a functional firearm in his home without a license. The district court dismissed the complaint. The U.S. Court of Appeals for the District of Columbia Circuit reversed and held that the Second Amendment protects the right to keep firearms in the home for the purpose of self-defense, and the District of Columbia’s requirement that firearms kept in the home be nonfunctional violated that right.</p>
1,301
5
4
false
majority opinion
affirmed
Criminal Procedure
1,871
55,494
Washington State Grange v. Washington State Republican Party
https://api.oyez.org/cases/2007/06-713
06-713
2007
Washington State Grange
Washington State Republican Party et al.
<p>The State of Washington reconstructed its primary election system according to Initiative 872, which was passed into law by a majority general vote in 2004. The initiative was endorsed by the Washington State Grange and created a new "modified blanket primary" system where each candidate on the ballot could affiliate with the party of his choosing regardless of whether the party approved of his candidacy. Political parties claimed that this system violated their First and Fourteenth Amendment rights of free association, arguing that control over which candidates to endorse constituted an essential function of association. The Grange argued that the primary was nonpartisan.</p> <p>The U.S. Court of Appeals for the Ninth Circuit affirmed a District Court decision, ruling that since "party designation is a powerful, partisan message that voters may rely upon in casting a vote," Initiative 872 "constitutes a severe burden upon the parties' associational rights." (The case was consolidated with <em>Washington v. Washington State Republican Party</em> for argument before the Supreme Court.)</p>
1,109
7
2
true
majority opinion
reversed
Civil Rights
1,872
55,496
Gonzalez v. United States
https://api.oyez.org/cases/2007/06-11612
06-11612
2007
Homero Gonzalez
United States
<p>Homero Gonzalez was tried with a co-defendant on several drug-related charges. He pled not guilty and opted for a jury trial. When jury selection began, a magistrate judge who had presided over several pretrial matters announced that she would conduct voir dire, and sought consent from the parties. Attorneys for the government and for Gonzalez expressly agreed. Gonzalez, who was being assisted by a translator, was not directly asked to consent, nor did he affirmatively object. He argued on appeal that he had the right to a new trial because he did not give his personal consent for a magistrate to conduct the jury interviews.</p>
640
8
1
false
majority opinion
affirmed
Criminal Procedure
1,873
55,495
United States v. Clintwood Elkhorn Mining Co.
https://api.oyez.org/cases/2007/07-308
07-308
2007
United States
Clintwood Elkhorn Mining Company, et al.
<p>In 2000, the IRS announced it was admitting the unconstitutionality of a 1978 coal export tax. In response, Clintwood Elkhorn Mining brought suit to recover funds paid, plus interest, under the unconstitutional tax scheme between the years 1994 and 1999. Clintwood sought recovery under the Export Clause of the Tucker Act, 28 U.S.C Section 1491, which applies a six-year statute of limitations to claims and makes no mention of interest payments. The government argued that such claims must be brought under the Tax Code, which allows interest but applies a three-year statute of limitations.</p> <p>Both the Court of Federal Claims and the U.S. Court of Appeals for the Federal Circuit allowed the Tucker Act claims, but the circuit court overruled the federal claims court's decision denying interest payments. In urging the Court to review both conclusions, the government contended that the Federal Circuit's ruling was at odds with other circuit decisions prohibiting Tucker Act claims under similar circumstances.</p>
1,028
9
0
true
majority opinion
reversed
Federal Taxation
1,874
55,493
Sprint/United Management Co. v. Mendelsohn
https://api.oyez.org/cases/2007/06-1221
06-1221
2007
Sprint/United Management Company
Ellen Mendelsohn
<p>During a company-wide reduction in force, Sprint fired fifty-one-year-old employee Ellen Mendelsohn. Mendelsohn sued, alleging that Sprint had discriminated against her on account of age in violation of the Age Discrimination in Employment Act. At the trial, Mendelsohn attempted to present evidence from other Sprint employees who alleged that they were also discriminated against by the company. This type of testimony by employees who are not parties to the case is sometimes called "me, too" testimony. The District Court judge refused to admit the testimony, citing the "same supervisor" rule. Since the other employees did not share a supervisor with Mendelsohn, their testimony was not relevant to the alleged discriminatory intent behind the decision to fire her.</p> <p>The jury returned a verdict for Sprint, but on appeal the U.S. Court of Appeals for the Tenth Circuit reversed and ordered a new trial. The Tenth Circuit held that the "same supervisor" rule applies only to discriminatory disciplinary actions and not to suits alleging a company-wide policy of discrimination. The Tenth Circuit held that the "me, too" testimony was relevant because the other employees were similarly situated and fired around the same time, and it held that the testimony was important enough that its exclusion had denied Mendelsohn an opportunity to present her allegation of company-wide discrimination. The ruling conflicted with those of several other Circuit Courts which approved the exclusion of "me, too" testimony.</p>
1,529
9
0
true
majority opinion
vacated/remanded
Civil Rights
1,875
55,497
Greenlaw v. United States
https://api.oyez.org/cases/2007/07-330
07-330
2007
Michael Greenlaw, aka Mikey
United States
<p>When Michael Greenlaw was convicted of several drug and firearm offenses in federal court, the prosecution argued that he should receive a mandatory minimum sentencing hike because he had been convicted of two counts under the federal gun law. The district judge, in a decision incorrect under the Supreme Court's holding in Deal v. United States, reasoned that the mandatory minimum should not apply because the second offense was not the result of a separate, pre-existing indictment.</p> <p>On appeal, the U.S. Court of Appeals for the Eight Circuit vacated the sentence and sent the case back to the district court with instructions to apply the mandatory minimum. In seeking certiorari, Greenlaw argued that the Eight Circuit had ignored substantial high court precedent holding that an appellate court may not order a higher criminal sentence without a government request to do so. Greenlaw further sought clarification of two related issues: whether the lack of a government appeal deprives the appellate court of authority as a matter of jurisdiction or merely as a custom of practice, and whether such appellate court discretion is allowable under Federal Rule of Criminal Procedure 52(b), which allows courts to consider plain errors even when the parties do not raise them. The Solicitor General, while agreeing with Greenlaw that the Eighth Circuit erred, urged the Court to grant certiorari and remand the case for further briefing in order to give the appellate court an opportunity to revisit its holding.</p>
1,528
6
3
true
majority opinion
vacated/remanded
Judicial Power
1,876
55,498
Boumediene v. Bush
https://api.oyez.org/cases/2007/06-1195
06-1195
2007
Lakhdar Boumediene et al.
George W. Bush, President of the United States, et al.
<p>In 2002 Lakhdar Boumediene and five other Algerian natives were seized by Bosnian police when U.S. intelligence officers suspected their involvement in a plot to attack the U.S. embassy there. The U.S. government classified the men as enemy combatants in the war on terror and detained them at the Guantanamo Bay Naval Base, which is located on land that the U.S. leases from Cuba. Boumediene filed a petition for a writ of habeas corpus, alleging violations of the Constitution's Due Process Clause, various statutes and treaties, the common law, and international law. The District Court judge granted the government's motion to have all of the claims dismissed on the ground that Boumediene, as an alien detained at an overseas military base, had no right to a habeas petition. The U.S. Court of Appeals for the D.C. Circuit affirmed the dismissal but the Supreme Court reversed in <em>Rasul v. Bush</em>, which held that the habeas statute extends to non-citizen detainees at Guantanamo.</p> <p>In 2006, Congress passed the Military Commissions Act of 2006 (MCA). The Act eliminates federal courts' jurisdiction to hear habeas applications from detainees who have been designated (according to procedures established in the Detainee Treatment Act of 2005) as enemy combatants. When the case was appealed to the D.C. Circuit for the second time, the detainees argued that the MCA did not apply to their petitions, and that if it did, it was unconstitutional under the Suspension Clause. The Suspension Clause reads: "The Privilege of the Writ of Habeas Corpus shall not be suspended, unless when in Cases of Rebellion or Invasion the public Safety may require it."</p> <p>The D.C. Circuit ruled in favor of the government on both points. It cited language in the MCA applying the law to "all cases, without exception" that pertain to aspects of detention. One of the purposes of the MCA, according to the Circuit Court, was to overrule the Supreme Court's opinion in <em>Hamdan v. Rumsfeld</em>, which had allowed petitions like Boumediene's to go forward. The D.C. Circuit held that the Suspension Clause only protects the writ of habeas corpus as it existed in 1789, and that the writ would not have been understood in 1789 to apply to an overseas military base leased from a foreign government. Constitutional rights do not apply to aliens outside of the United States, the court held, and the leased military base in Cuba does not qualify as inside the geographic borders of the U.S. In a rare reversal, the Supreme Court granted certiorari after initially denying review three months earlier.</p>
2,608
5
4
true
majority opinion
reversed
Criminal Procedure
1,877
55,500
Engquist v. Oregon Department of Agriculture
https://api.oyez.org/cases/2007/07-474
07-474
2007
Anup Engquist
Oregon Department of Agriculture et al.
<p>Anup Engquist, a woman of Indian descent, brought this action against the Oregon Department of Agriculture alleging that a co-worker at the Department harassed her and eventually engineered her termination. Although Engquist asserted numerous claims, a jury in the federal district court only found in her favor on her equal protection, substantive due process, and intentional interference with employment claims.</p> <p>On appeal, the U.S. Court of Appeals for the Ninth Circuit struck those jury verdicts. Although the Ninth Circuit acknowledged that the Supreme Court had previously dealt with such "class of one" equal protection claims eight years ago in a case, <em>Village of Willowbrook v. Olech</em>, involving a village resident suing the village for unjustified zoning decisions, it refused to apply that short, two-page opinion to Engquist's claim. The Ninth Circuit reasoned that the Olech opinion may only apply when the government is in the role of regulator and did not clarify whether it would also apply in an employment context such as this one. In seeking Court review, Engquist noted the pervasive splits in the circuits regarding the proper allocation of the Court's decision in Olech, while Oregon claimed that Olech should be construed narrowly so as to avoid a deluge of petty cases against the government. Oregon also pointed out that even if the case were to be heard, Oregon would have qualified immunity and Engquist would necessarily lose.</p>
1,478
6
3
false
majority opinion
affirmed
Civil Rights
1,878
55,499
CSX Transportation, Inc. v. Georgia State Board of Equalization
https://api.oyez.org/cases/2007/06-1287
06-1287
2007
CSX Transportation, Inc.
Georgia State Board of Equalization et al.
<p>The Tax Injunction Act establishes a general rule that federal courts will not interfere with matters of state taxation, but the Railroad Revitalization and Regulatory Reform Act of 1976 (4-R Act) provides an exception for railroads. In an effort to prevent state tax discrimination against railroads, Section 306 of the 4-R Act requires that the ratio of the assessed value to the true market value of railroad property not exceed by more than five percent the ratio of assessed value to true market value for all other commercial and industrial property in the assessment jurisdiction. This calculation requires that states determine the "true market value" of the railroads' property - a valuation that can be subjective. Using a new valuation methodology, the Georgia State Board of Equalization appraised the property of the railroad company CSX Transportation, Inc. at $8.2 billion. CSX filed a complaint under the 4-R Act, noting that the old appraisal methodology would have valued the property at only $6 billion. Despite CSX's argument that the 4-R Act allows railroads to challenge state valuation methods, the district court ruled that the only the state's methodology could be considered.</p> <p>The U.S. Court of Appeals for the Eleventh Circuit affirmed the lower court. The Eleventh Circuit ruled that in the absence of a clear statement in the 4-R Act, principles of federalism weighed against interpreting the Act to give railroads additional power to challenge the taxing authority of the states in federal court. The Circuit Court stood by the general principle that federal courts should not interfere with state taxation policies. Since the 4-R Act did not allow challenges to the state's choice of valuation method, CSX could not bring its arguments that Georgia's methodology was faulty.</p>
1,819
9
0
true
majority opinion
reversed
Economic Activity
1,879
55,501
Chamber of Commerce of the U.S. v. Brown
https://api.oyez.org/cases/2007/06-939
06-939
2007
Chamber of Commerce of the United States of America et al.
Edmund G. Brown, Jr., Attorney General of California, et al.
<p>After the California legislature passed laws prohibiting the use of state funds to "assist, promote, or deter union organizing," a group of California companies brought suit claiming the state laws were preempted by the National Labor Relations Act, 29 U.S.C. Section 7. The Act provides that companies' anti-labor speech can only be considered evidence of unfair labor practice if it threatens or coerces workers. The California companies argued that the state laws infringe upon their "safe harbor" for anti-labor speech embodied in the Act.</p> <p>The U.S. Court of Appeals for the Ninth Circuit, after entering two panel decisions holding the California law preempted, issued a split en banc opinion holding that it was not. The Second Circuit has reached the opposite conclusion on similar facts. The Court's decision in this case will affect roughly a dozen other states currently considering adopting legislation substantially similar to the California law.</p>
972
7
2
true
majority opinion
reversed/remanded
Federalism
1,880
55,505
New York State Board of Elections v. Lopez Torres
https://api.oyez.org/cases/2007/06-766
06-766
2007
New York State Board of Elections et al.
Margarita Lopez Torres et al.
<p>New York trial court judges are appointed by way of a "district convention system." Under this system, political party members elect delegates, who in turn vote for judicial candidates nominated at party conventions. Margarita Lopez Torres sought appointment to a New York Supreme Court but did not have a political party's endorsement. Lopez Torres claimed that the system unconstitutionally obstructed judicial appointments by making candidates reliant upon political parties. The New York Board of Elections defended the system, arguing that it did not bar voters from participating because they had the opportunity to elect delegates.</p> <p>A District Court found that the system unnecessarily and excessively restricted elections. It cited the absence of a "single successful challenge to candidates backed by the party leaders." The U.S. Court of Appeals for the Second Circuit affirmed that the system gave political party officials too much power and violated voters' and candidates' First Amendment rights to freedom of association.</p>
1,050
9
0
true
majority opinion
reversed
First Amendment
1,881
55,504
Kennedy v. Louisiana
https://api.oyez.org/cases/2007/07-343
07-343
2007
Patrick Kennedy
State of Louisiana
<p>A Louisiana court found Patrick Kennedy guilty of raping his eight-year-old stepdaughter. Louisiana law allows the district attorney to seek the death penalty for defendants found guilty of raping children under the age of twelve. The prosecutor sought, and the jury awarded, such a sentence; Kennedy appealed.</p> <p>The Louisiana Supreme Court affirmed the imposition of the death sentence, noting that although the U.S. Supreme Court had struck down capital punishment for rape of an adult woman in <em>Coker v. Georgia</em>, that ruling did not apply when the victim was a child. Rather the Louisiana high court applied a balancing test set out by the Court in <em>Atkins v. Virginia</em> and <em>Roper v. Simmons</em>, first examining whether there is a national consensus on the punishment and then considering whether the court would find the punishment excessive. In this case, the Louisiana Supreme Court felt that the adoption of similar laws in five other states, coupled with the unique vulnerability of children, justified imposing the death penalty.</p> <p>In seeking certiorari, Kennedy argued that five states do not constitute a "national consensus" for the purposes of Eighth Amendment analysis, that <em>Coker v. Georgia</em> should apply to all rapes regardless of the age of the victim, and that the law was unfair in its application, singling out black child rapists for death at a significantly higher rate than whites.</p>
1,450
5
4
true
majority opinion
reversed/remanded
Criminal Procedure
1,882
55,506
Logan v. United States
https://api.oyez.org/cases/2007/06-6911
06-6911
2007
James D. Logan
United States
<p>Four-time convicted felon James Logan received an enhanced sentence of 15 years under the Armed Career Criminal Act (ACCA) after his conviction for firearm possession. The ACCA imposes heavier penalties upon felons convicted of three or more violent crimes. Logan contended that his three battery convictions did not count toward the three-conviction threshold because none of them had resulted in the loss of his civil rights. (Battery is a misdemeanor in Wisconsin, but it qualifies as a violent crime under the ACCA.) Since the ACCA excludes those violent crime convictions for which civil rights have been restored to the felon, Logan argued that convictions that never stripped him of his civil rights should be excluded as well.</p> <p>A District Court ruled against Logan because a literal reading of the ACCA excluded only those who have "had civil rights restored." The United States Court of Appeals for the Seventh Circuit affirmed that it is impossible to restore civil rights that are never taken away, and that Logan's battery convictions must therefore be counted under the ACCA.</p>
1,102
9
0
false
majority opinion
affirmed
Criminal Procedure
1,883
55,507
Burgess v. United States
https://api.oyez.org/cases/2007/06-11429
06-11429
2007
Keith Lavon Burgess
United States
<p>When Keith Burgess pleaded guilty to a drug distribution charge in 2003, the government requested that his statutory minimum sentence be increased from ten to twenty years. The government based this request on 21 U.S.C. Section 841(b)(1)(A), which requires such a sentencing hike for defendants with prior felony drug convictions. The statute defined "felony drug offense" as any felony under any provision of the statute or any other federal law. Burgess argued that this definition conflicts with 21 U.S.C. Section 802(13) which requires that a felony drug offense be punishable by imprisonment for more than a year. Therefore, any enhancement of his sentence must be barred unless both statutory definitions are fulfilled. Although the U.S. Court of Appeals for the Fourth Circuit rejected Burgess' argument, the D.C. Circuit reached the opposite conclusion based on similar facts in 2004.</p>
900
9
0
false
majority opinion
affirmed
Criminal Procedure
1,884
55,509
Giles v. California
https://api.oyez.org/cases/2007/07-6053
07-6053
2007
Dwayne Giles
California
<p>When Dwayne Giles was tried in state court for the murder of his ex-girlfriend, he claimed self-defense. Giles stated that he had heard her vow to hurt him and a friend, and that she had previously shot a man and threatened people with knives. The prosecution then introduced evidence of a conversation between Giles' ex-girlfriend and police in which she claimed that he had assaulted her and threatened to kill her. The district court eventually convicted Giles of murder.</p> <p>On appeal, Giles argued that use of the police conversation violated his Sixth Amendment right to confront witnesses against him, namely, his deceased ex-girlfriend. The California Supreme Court held that Giles had waived this right because he was the cause of his ex-girlfriend's absence. Although this exclusion was justified under common law rules of "forfeiture by wrongdoing", the Supreme Court had greatly constrained the admissibility of such evidence in its 2004 holding in <em>Crawford v. Washington.</em> <em>Crawford</em> essentially wiped out the admissibility of such out-of-court statements unless the testimony could be subject to cross-examination at trial, an option that would be impossible under these circumstances. This case gives the Court an opportunity to expand on its decision in <em>Crawford</em> and to apply it to a situation where the wrongdoing that kept the witness from appearing in court was not motivated by a desire to prevent the witness' testimony.</p>
1,476
6
3
true
majority opinion
vacated/remanded
Criminal Procedure
1,885
55,508
Regalado Cuellar v. United States
https://api.oyez.org/cases/2007/06-1456
06-1456
2007
Humberto Fidel Regalado Cuellar
United States
<p>Humberto Fidel Regaldo Cuellar was apprehended in 2004 driving a Volkwagen Beetle crawling 30 miles below the speed limit on a main artery through Texas to Mexico. When police pulled Cuellar over, they discovered that he had logged about 1,000 miles in the past two days stopping in major cities along the way for just hours each time. When questioned, Cuellar acted nervously; he later turned over a large roll of cash that smelled like marijuana. When police examined the car, they found drill marks suggesting tampering with the gas tank, as well as mud splashings and animal hair typical of efforts to conceal the existence of contraband. Police found $83,000 in cash in a secret compartment beneath the floorboard. Cuellar was convicted of money laundering, but the appeals court overturned the conviction. The court ruled that the federal money laundering statute required the government to prove that Cuellar was attempting to portray the money he carried as legitimate wealth, rather than merely showing that he tried to hide it.</p>
1,045
9
0
true
majority opinion
reversed
Criminal Procedure
1,886
55,510
Quanta Computer, Inc., et al. v. LG Electronics, Inc.
https://api.oyez.org/cases/2007/06-937
06-937
2007
Quanta Computer, Inc., et al.
LG Electronics, Inc.
<p>LG Electronics owned patents for a group of products, including microprocessor chips used in personal computers. It licensed the patents to Intel, but in a well-publicized separate agreement excluded from the license any Intel customer that integrated the chip with non-Intel components. One purchaser disregarded the agreement and used the chips in computers made for Dell, Hewlett-Packard and Gateway. LG Electronics sued those who passed the chips down the line of commerce to companies that had not purchased licenses.</p>
530
9
0
true
majority opinion
reversed
Economic Activity
1,887
55,512
Gall v. United States
https://api.oyez.org/cases/2007/06-7949
06-7949
2007
Brian Michael Gall
United States
<p>While a student at the University of Iowa, Brian Gall was involved in a drug ring distributing ecstasy (methylenedioxymethamphetamine, MDMA). He voluntarily left the drug conspiracy and moved to Arizona where he started his own business and led a crime-free life. When federal agents tracked him down, he turned himself in and pleaded guilty to conspiracy to distribute a controlled substance. The government argued for a sentence of 30 months in prison, which was the minimum sentence in the range recommended for the offense by the federal sentencing guidelines. Taking into account the mitigating circumstances in Gall's case, the judge instead decided to depart from the guidelines and impose a sentence of 36 months of probation. (The Supreme Court in <em>U.S. v. Booker</em> had declared the sentencing guidelines to be merely advisory, but the guidelines range is still among the factors a court must consider before handing down a reasonable sentence.)</p> <p>The U.S. Court of Appeals for the Eighth Circuit rejected the below-guidelines sentence as unreasonable. The Eighth Circuit held that while the guidelines are not mandatory, sentences that fall outside of the recommended sentencing range must overcome a presumption of unreasonableness. Sentences varying from the guidelines must be justified based on the circumstances of the case, and larger variances from the guidelines require correspondingly more compelling justifications. The Eighth Circuit ruled that the district court had erred by using Gall's youth as a mitigating factor, by overweighing his rehabilitation, and by underweighing the seriousness of the crime. Since the "extraordinary variance" was not justified by a finding of extraordinary circumstances, the Eighth Circuit ordered a new sentence.</p>
1,788
7
2
true
majority opinion
reversed
Criminal Procedure
1,888
55,511
United States v. Rodriquez
https://api.oyez.org/cases/2007/06-1646
06-1646
2007
United States
Gino Gonzaga Rodriquez
<p>When Gino Rodriquez was released from prison on supervision, he promptly absconded and was later found with $900 cash, heroin and a gun. Prosecutors argued that Rodriquez was subject to the Armed Career Criminal Act, which applies to those convicted of being a felon in possession of a firearm if they have a total of three previous convictions for violent felonies or serious drug offenses. Rodriquez had two California burglary convictions. Prosecutors argued that the third required conviction was supplied by Rodriquez's Washington drug offenses. Although none of the three drug convictions, on their own, was considered "serious," the second and third were repeat offenses and therefore punishable by ten-year sentences sufficient to qualify as serious under the federal career criminal law.</p>
804
6
3
true
majority opinion
reversed/remanded
Criminal Procedure
1,889
55,513
Department of Revenue of Kentucky v. Davis
https://api.oyez.org/cases/2007/06-666
06-666
2007
Department of Revenue of Kentucky et al.
George W. Davis et ux.
<p>When calculating gross income for tax purposes, the Internal Revenue Code exempts from taxation the interest earned on any state or local bond. However, Kentucky law requires that interest income earned on bonds issued by other states be taxed as part of an individual's adjusted gross income. George and Catherine Davis filed a class action complaint arguing that Kentucky's policy of taxing out-of-state bonds was in violation of the dormant Commerce Clause - the doctrine that the Commerce Clause forbids states from interfering with interstate commerce. The state trial court ruled in favor of the Kentucky Department of Revenue and declared the tax policy constitutional.</p> <p>On appeal, the Davises stressed Kentucky's market discrimination against other states as a factor indicating that the policy was unconstitutional. In response, the Department of Revenue cited a similar policy that was upheld by state courts in Ohio. The Department also invoked the "market participant doctrine," which stands for the idea that only the state's actions as a regulator are subject to the dormant Commerce Clause. Actions undertaken as a market participant, such as the issuance of bonds, are not. The Kentucky Court of Appeals reversed the lower court and struck down the tax policy. The Court of Appeals held that the tax discrimination rather than the bond issuance was at issue, and the taxation was indisputably undertaken in the state's capacity as a regulator. The court concluded that the Commerce Clause was incompatible with such a discriminatory state policy.</p>
1,576
7
2
true
majority opinion
reversed
Economic Activity
1,890
55,514
New Jersey v. Delaware
https://api.oyez.org/cases/2007/134-orig
134-orig
2007
State of New Jersey
State of Delaware
<p>When British Petroleum (BP) wanted to build a natural gas transfer facility on the New Jersey side of the Delaware River, the State of Delaware objected that the pier construction would require the dredging of underwater lands it considered part of its coastal zone. Delaware denied BP a permit for the construction despite the fact that most of the construction would take place on the New Jersey side of the river. New Jersey granted the permit, arguing that a 1905 compact between the States settling a boundary dispute placed the construction site under New Jersey control. New Jersey filed a claim to settle the dispute and the case went directly to the Court under its original jurisdiction to hear disputes between two States.</p>
741
5
3
null
majority opinion
null
null
1,891
55,515
Virginia v. Moore
https://api.oyez.org/cases/2007/06-1082
06-1082
2007
Commonwealth of Virginia
David Lee Moore
<p>Virginia police stopped David Lee Moore after receiving a radio call alerting them that he was driving on a suspended license. State law specified the procedure for punishing that infraction: issuance of a citation and summons to appear in court. The officers instead decided to arrest Moore. After reading Moore his Miranda rights, they asked for and received consent to search his hotel room. Once they arrived at the room, they decided to search his person and discovered sixteen grams of crack cocaine. Moore was then charged with possession of cocaine with intent to distribute.</p> <p>At trial court, Moore's attorney sought to suppress the cocaine evidence, arguing that it was seized in violation of the Fourth Amendment. The trial court allowed the evidence to be presented and Moore was convicted. On appeal, the Virginia Supreme Court held that the introduction of the cocaine evidence at trial was unconstitutional.</p>
935
9
0
true
majority opinion
reversed/remanded
Criminal Procedure
1,892
55,516
CBOCS West, Inc. v. Humphries
https://api.oyez.org/cases/2007/06-1431
06-1431
2007
CBOCS West, Inc.
Hedrick G. Humphries
<p>Hendrick Humphries, an African-American, was an associate manager at a Cracker Barrel restaurant owned by CBOCS. After he was fired, Humphries filed a lawsuit claiming discrimination and retaliation under 42 USC Section 1981. Humphries alleged that retaliation took many forms of abuse by his superiors. Section 1981, which derives from the Civil Rights Act of 1866, states in part that "All persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exactions of every kind, and to no other."</p> <p>Humphries lost his case in federal district court but on appeal, the U.S. Court of Appeals for the Seventh Circuit held that Section 1981 protects against retaliation.</p>
1,007
7
2
false
majority opinion
affirmed
Civil Rights
1,893
55,517
Riley v. Kennedy
https://api.oyez.org/cases/2007/07-77
07-77
2007
Bob Riley, Governor of Alabama
Yvonne Kennedy et al.
<p>In 1987, the United States Attorney General precleared a local Alabama law providing for a special election to fill vacancies on the Mobile County Commission, an exception to the usual procedure of gubernatorial appointment. The Alabama Supreme Court subsequently ruled that the election violated the Alabama Constitution, so in response the Alabama Legislature passed an act explicitly allowing local laws to establish such an election. The Alabama Supreme Court rejected this contention and held that the new state law failed to revive the local law. The plaintiffs, a group of Alabama residents, brought this suit in federal court alleging that Section 5 of the Voting Rights Act of 1965 required the State of Alabama to preclear the two decisions of the Supreme Court in an action against the Governor of Alabama.</p> <p>The U.S. District Court for the Middle District of Alabama found for the plaintiffs, stating that because the local law was the most recent precleared practice put into effect with the 1987 special election, it was the baseline from which to determine if there was a change. Because the Alabama Supreme Court had rendered the local law invalid and the state law unenforceable, the two decisions represented changes that should have been precleared before being implemented.</p>
1,306
7
2
true
majority opinion
reversed/remanded
Civil Rights
1,894
55,518
Taylor v. Sturgell
https://api.oyez.org/cases/2007/07-371
07-371
2007
Brent Taylor
Robert A. Sturgell, Acting Administrator, Federal Aviation Administration, et al.
<p>Greg Herrick, the owner of one of two F-45s, a rare 1930s vintage airplane, in existence filed a Freedom of Information Act (FOIA) request seeking the plans and specifications for the craft from the Federal Aviation Administration. After the FAA refused to turn over the plans as "protected trade secrets," Herrick filed suit against the FAA to recover the plans. The district court found for the FAA, and the U.S. Court of Appeals for the Tenth Circuit affirmed. Subsequently, roughly a month later, Brent Taylor, represented by Herrick's attorney, filed another FOIA request seeking the plans. When the request was again denied, Taylor also filed suit in federal court in the District of Columbia.</p> <p>The district court determined that Taylor had been "virtually represented" by Herrick in the first suit and therefore could not pursue the second suit in federal court. This judgment was affirmed by the U.S. Court of Appeals for the D.C. Circuit. In seeking Supreme Court review, Taylor argued the D.C. Circuit's finding that Taylor and Herrick enjoyed a close enough relationship for virtual representation to apply conflicted with several other circuits requiring a much closer nexus to block the second claim. Opposing certiorari, Fairchild Corp. (the airplane manufacturer) arguing on behalf of the FAA, claimed that Taylor had overstated the circuit splits. It also pointed out that, because Taylor and Herrick were collaborating on the plane restoration and were represented by the same attorney, the logical conclusion was that they were attempting to relitigate the same issue.</p>
1,600
9
0
true
majority opinion
vacated/remanded
Judicial Power
1,895
55,519
Stoneridge Investment Partners, LLC v. Scientific-Atlanta, Inc.
https://api.oyez.org/cases/2007/06-43
06-43
2007
Stoneridge Investment Partners, LLC
Scientific-Atlanta, Inc., et al.
<p>Stoneridge Investment Partners alleged that the cable company Charter Communications had fraudulently inflated the price of its stock. The alleged scheme involved a "sham transaction" in which Charter gave its equipment vendor, Scientific-Atlanta, above-normal payments for T.V. set-top boxes and the vendor then gave back the extra payments as advertising fees. Charter then fraudulently accounted the returned payments as revenue. Stoneridge sued both Charter and Scientific-Atlanta under Section 10(b) of the Securities Exchange Act of 1934, but the district court threw out the claim against Scientific- Atlanta. The court ruled that Stoneridge's claim against the vendor was only a claim for aiding and abetting fraud.</p> <p>The Supreme Court had ruled in <em>Central Bank of Denver v. First International Bank of Denver</em> that Section 10(b) punishes only deceptive conduct itself, not aiding and abetting such conduct. However, the Court that secondary actors such as banks, lawyers, and accountants can be considered violators of Section 10(b) if they engage in deceptive conduct along with the primary actor. On appeal, Stoneridge argued that Scientific-Atlanta qualified as a primary violator of Section 10(b). Scientific-Atlanta countered that it had not participated in Charter's fraudulent accounting practices, and, in contrast to Charter, it had made no false public statements. The U.S. Court of Appeals for the Eighth Circuit ruled for Scientific Atlanta. The Circuit Court held that the vendor could at most be accused of aiding and abetting Charter's deception, and such claims are not allowed under Section 10(b) according to the Supreme Court's decision in <em>Central Bank</em>.</p>
1,711
5
3
false
majority opinion
affirmed
Economic Activity
1,896
55,520
Irizarry v. United States
https://api.oyez.org/cases/2007/06-7517
06-7517
2007
Richard Irizarry
United States
<p>In 2004, Richard Irizarry pleaded guilty to threatening his ex-wife. The district court sentenced Irizarry to five years, the maximum sentence allowed by law. The court imposed this sentence, which is six months longer than the sentence prescribed by the Federal Sentencing Guidelines, because it felt Irizarry was likely to continue to threaten his ex-wife.</p> <p>Irizarry appealed, arguing that the district court violated Rule 32(h) of the Federal Rules of Criminal Procedure by not giving advance notice that it was considering a ground for departure not identified in the presentence report or a prehearing government submission. The U.S. Court of Appeals for the Eleventh Circuit rejected this claim, stating that the Supreme Court's 2005 decision in U.S. v. Booker had made the guidelines advisory as opposed to mandatory. In imposing a harsher sentence than that suggested by the federal guidelines, the Eleventh Circuit reasoned, the district judge had merely varied the federal rules, not departed from them.</p>
1,027
5
4
false
majority opinion
affirmed
Criminal Procedure
1,897
55,521
Hall Street Associates, L.L.C. v. Mattel, Inc.
https://api.oyez.org/cases/2007/06-989
06-989
2007
Hall Street Associates, L.L.C.
Mattel, Inc.
<p>Toy manufacturer Mattel was sued by its landlord Hall Street Associates in a dispute over a property lease. After the litigation went to federal court both parties agreed to resolve the case by arbitration according to the procedures outlined in the Federal Arbitration Act (FAA). Atypically, the parties' arbitration agreement stipulated that the District Court could override the arbitrator's decision if "the arbitrator's conclusions of law are erroneous." This provision of the agreement granted the federal courts a much broader role in supervising the arbitration than is specifically granted in the FAA. The Act explicitly mentions only a narrow set of circumstances under which courts can override an arbitration award, such as corruption, partiality, or misbehavior on the part of the arbitrator.</p> <p>The arbitrator heard the parties' arguments and handed down a decision in favor of Mattel. Hall sought review from the District Court, and that court found that the arbitrator's decision contained legally erroneous conclusions. Accordingly, the arbitrator ruled for Hall Street, and the District Court affirmed.</p> <p>On appeal, the U.S. Court of Appeals for the Ninth Circuit ruled that the original arbitration award favoring Mattel must stand. Even if the arbitrator did make legal errors, it was not the place of the courts to review the soundness of the arbitrator's decision. The Ninth Circuit viewed the FAA's list of circumstances meriting judicial review as an exclusive list. As far as the original arbitration agreement expanded the scope of judicial review of the arbitration, the agreement could not be enforced.</p>
1,647
6
3
false
majority opinion
vacated/remanded
Economic Activity
1,898
55,524
Bridge v. Phoenix Bond & Indemnity Co.
https://api.oyez.org/cases/2007/07-210
07-210
2007
John Bridge et al.
Phoenix Bond & Indemnity Company et al.
<p>Property owners in Cook County, Illinois neglected to pay their tax bills and the county acquired liens on their real estate. John Bridge and Phoenix Bond &amp; Indemnity Co. mailed competing bids for the real estate liens when they were auctioned off by the county. Property liens are distributed proportionally to the parties seeking the lowest penalty from the original owner. After Bridge and Phoenix tied for the best bid, they were required to mail affidavits to the county stating that they were bidding in their own names and were not related to any other bidders. Subsequently, Phoenix filed suit against Bridge claiming the affidavits he sent were false and hid the fact that he was actually in collusion with other bidders, thereby obtaining more than his fair share of the liens. The district court held Phoenix lacked standing because Bridge had made the false statements to the county, not Phoenix.</p> <p>The U.S. Court of Appeals for the Seventh Circuit reversed, stating that Phoenix had suffered injury in fact proximately caused by Bridge. In seeking certiorari, Bridge noted splits between the circuits on the issue of whether a plaintiff must plead and prove reliance on a false statement in a RICO claim. Although Phoenix suggested that proximate cause, not reliance or standing, was the ultimate issue in this case, the Court has decided to frame its review around the reliance issue.</p>
1,415
9
0
false
majority opinion
affirmed
Economic Activity
1,899
55,523
Watson v. United States
https://api.oyez.org/cases/2007/06-571
06-571
2007
Michael A. Watson
United States
<p>Michael Watson was arrested for trading illegal drugs for an unloaded semi-automatic pistol. He was convicted of drug trafficking and sentenced to 262 months in prison. Since Watson's crime involved a gun, his sentence included an additional 60 months. The extra jail time was imposed under 18 U.S.C. 924(c)(1)(A), which punishes any drug trafficker who "uses or carries" a firearm during a drug deal. In <em>Smith v. United States</em>, the Supreme Court had ruled that a defendant who trades a gun for drugs "uses" it for purposes of the statute. However, the Court clarified in <em>Bailey v. United States</em> that "use" means "active employment" of a firearm; mere possession of the firearm does not necessarily constitute use.</p> <p>On appeal, Watson argued that the firearm was not used in his case. He stressed that the gun was never loaded and was in his possession for only moments before he was arrested. The U.S. Court of Appeals for the Fifth Circuit rejected Watson's arguments and affirmed the lower court. Following Circuit precedents, it ruled that Watson had used the gun under the statute's meaning of "use."</p>
1,136
9
0
true
majority opinion
reversed/remanded
Criminal Procedure